DEFENSE 

TRANSPORTATION

DOD Needs to Take 

Actions to Improve the 

Transportation of 

Hazardous Material 

Shipments

Report to Congressional Committees

May 2014

GAO-14-375

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-14-375, a report to 

congressional committees

May 2014

DEFENSE TRANSPORTATION

DOD Needs to Take Actions to Improve the 

Transportation of Hazardous Material Shipments

Why GAO Did This Study

Over 3 billion tons of HAZMAT are 

transported by commercial carriers in 

the United States each year. DOD 

accounted for about 1.6 million 

HAZMAT shipments in fiscal year 

2013, using commercial and military 

carriers. These shipments can be high 

risk and highly sensitive and if 

improperly handled, labeled, or 

packaged could result in the loss of 

life, property damage, and harm to 

national security interests.

The National Defense Authorization 

Act for Fiscal Year 2013 mandates 

GAO to review DOD’s guidance, 

policies, and procedures regarding 

HAZMAT shipments. GAO examined 

the (1) statutes, regulations, guidance, 

policies, and procedures that govern 

DOD’s handling, labeling, and 

packaging of HAZMAT shipments to 

support military operations and (2) 

extent to which DOD faces any 

challenges in implementing its policies 

and procedures for transporting 

HAZMAT in a safe, timely, and costeffective manner. GAO examined

DOD’s and DOT’s regulations and 

related DOD documentation for the 

transport of HAZMAT and found the 

2009-13 data it examined sufficiently 

reliable for the purposes of the review.

What GAO Recommends

GAO recommends that DOD improve 

the documentation and secure hold of 

HAZMAT shipments and examine 

limitations on data used to select 

certain HAZMAT carriers. DOD 

generally agreed with the 

recommendations but requested one 

be directed to a different office. GAO 

agreed and made the associated 

change.

What GAO Found

The handling, labeling, and packaging of hazardous materials (HAZMAT)

shipments are governed by a complex framework of statutes and regulations 

prescribed by multiple civilian and military entities (see figure below). The 

Hazardous Materials Transportation Act is the primary statutory regime 

governing the transport of HAZMAT in the United States. To implement the act, 

the Department of Transportation (DOT) issued the Hazardous Materials 

Regulations. The Defense Transportation Regulation prescribes how the 

Department of Defense (DOD) is to transport HAZMAT.

Existing Statutory and Regulatory Elements That Department of Defense Incorporated into the 

Defense Transportation Regulation and Other Guidance

DOD has experienced some challenges in implementing HAZMAT regulations 

and other guidance, which can adversely affect the safe, timely, and costeffective transportation of HAZMAT. For example, GAO found the following:

• Improper documentation and packaging of HAZMAT led to delays at DOD 

transportation aerial ports. DOD data show that about 27 percent of HAZMAT

received at all five major domestic military aerial ports over the past 5 fiscal 

years were delayed, primarily due to noncompliant documentation and 

packaging.

• At least 44 times during fiscal years 2012 and 2013, DOD installations did 

not provide commercial carriers with access to secure hold areas for arms, 

ammunition, and explosives shipments or assist them in finding alternatives,

as required by DOD regulations. Although there were about 70,891 of these 

types of arms, ammunition, and explosives shipments in fiscal years 2012 

and 2013, not providing secure hold for even a small percentage of these 

sensitive shipments poses a risk to public safety and national security. 

• DOD may determine which carriers should be eligible to transport its mostsensitive HAZMAT shipments using a safety score that lacks sufficient 

information to reliably assess safety performance for many carriers. DOD 

uses DOT’s Safety Measurement System scores to determine which carriers 

are eligible to participate in its Transportation Protective Services program. 

However, in February 2014 GAO found that scores from many carriers lack 

sufficient safety performance data to reliably compare them with other 

commercial carriers’ scores.

View GAO-14-375. For more information, 

contact Cary B. Russell at (202) 512-5431 or 

russellc@gao.gov.
Page i GAO-14-375 Defense Transportation

Letter 1

Background 4

The Handling, Labeling, and Packaging of DOD HAZMAT 

Shipments Is Governed by a Complex Framework of Statutes 

and Regulations 11

DOD Has Experienced Some Challenges in Implementing 

HAZMAT Policies and Procedures, Which Can Adversely Affect 

the Safe, Timely, and Cost-Effective Transportation of HAZMAT 17

Conclusions 30

Recommendations for Executive Action 31

Agency Comments and Our Evaluation 32

Appendix I Scope and Methodology 36

Appendix II Comments from the Department of Defense 40

Appendix III GAO Contact and Staff Acknowledgments 43

Figures

Figure 1: Examples of the Department of Transportation’s (DOT) 

Labels for the Nine Classes of Hazardous Materials 

(HAZMAT) 5

Figure 2: Functions That a Shipper, Carrier, and Receiver Might 

Perform to Transport Hazardous Materials (HAZMAT) in 

Commerce 7

Figure 3: Example of Hazardous Materials (HAZMAT) 

Documentation Used for Transporting Arms, Ammunition, 

and Explosives by Air (Shipper’s Declaration for 

Dangerous Goods) 9

Figure 4: Example of Documentation and Packaging Used for 

Transporting a Biological Sample (HAZMAT Class 6) 10

Figure 5: Existing Statutory and Regulatory Elements That DOD 

Incorporated into the Defense Transportation Regulation 

and Other Guidance 13

Figure 6: Shipment of Improperly Packaged, Rusted Acetylene 

Gas Cylinders Delayed in Transport 19

Contents
Page ii GAO-14-375 Defense Transportation

Figure 7: Shipment of Improperly Packaged Flammable, Toxic 

Liquid Delayed in Transport 20

Abbreviations

DOD Department of Defense

DOT Department of Transportation

HAZMAT Hazardous Materials

TRANSCOM U.S. Transportation Command

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Page 1 GAO-14-375 Defense Transportation

441 G St. N.W.

Washington, DC 20548

May 1, 2014

Congressional Committees

Over 3 billion tons of hazardous materials (HAZMAT) are transported by 

commercial carriers in the United States each year, with an estimated 1.4 

million HAZMAT shipments per day.1 These range from sensitive 

materials commonly considered to pose a risk to national security (e.g., 

arms, ammunition and explosives, and nuclear-weapons-related 

materials) to those associated with everyday use (e.g., chlorine, fire 

extinguishers, and lithium batteries). HAZMAT at both ends of this 

spectrum can pose a significant threat to transportation workers, 

emergency responders, and the general public if the HAZMAT shipment 

is not properly handled, labeled, and packaged for transportation. Within 

the United States, the Department of Transportation (DOT) is the primary 

federal agency responsible for issuing regulations for the safe transport of 

HAZMAT in intrastate, interstate, and foreign commerce.2

The Department of Defense (DOD) transported approximately 1.6 million 

HAZMAT shipments in fiscal year 2013 using a mix of commercial and 

military carriers. The shipments the department transports can be high 

risk (e.g., explosives and toxins) as well as highly sensitive (e.g., missiles) 

and, if improperly handled, labeled, or packaged, could result in the loss 

of life, property damage, and harm to national security interests. DOD 

relies heavily (for about 90 percent of its total HAZMAT shipments) on 

commercial carriers to transport HAZMAT both within the United States 

and worldwide. Within DOD, the U.S. Transportation Command 

(TRANSCOM) is the functional combatant command charged with 

 1

A shipment may comprise several deliveries or orders and can use one or more modes 

of transportation (e.g., by rail and then by air).

2

See, e.g., 49 U.S.C. § 5103(b). As used in the Hazardous Materials Transportation Act, 

“commerce” refers to trade or transportation in the jurisdiction of the United States 

between a place in a state and a place outside that state; that affects trade or 

transportation between a place in a state and place outside that state; or on a U.S.-

registered aircraft. See 49 U.S.C. § 5102(1). Implementing regulations issued by the 

Department of Transportation further define the term to include trade or transportation in 

the jurisdiction of the United States within a single state. See 49 C.F.R. § 171.8.
Page 2 GAO-14-375 Defense Transportation

providing transportation services to the other combatant commands, 

military services, and defense organizations.3

The National Defense Authorization Act for Fiscal Year 2013 mandates 

GAO to review DOD’s guidance, policies, and procedures for the 

handling, labeling, and packaging of HAZMAT shipments, including how 

the guidance, policies, and procedures contribute to the safe, timely, and 

cost-effective handling of such material, among other matters.4

To examine the statutes, regulations, guidance, policies, and procedures 

that govern DOD’s handling, labeling, and packaging of HAZMAT 

shipments to support military operations, we reviewed the Hazardous 

Materials Transportation Act, as amended;

To 

respond to this mandate, we examined the (1) statutes, regulations, 

guidance, policies, and procedures that govern DOD’s handling, labeling, 

and packaging of HAZMAT shipments to support military operations and 

(2) extent to which DOD faces any challenges in implementing its policies 

and procedures for transporting HAZMAT in a safe, timely, and costeffective manner.

5 DOT’s Hazardous Materials 

Regulations in Title 49 of the Code of Federal Regulations;6 DOD 

guidance, including relevant sections of the Defense Transportation 

Regulation7 and Joint Publication 4-01—The Defense Transportation 

System;8

 3

Subject to the authority, direction, and control of the Secretary of Defense, the Chairman 

of the Joint Chiefs of Staff serves as the spokesperson for the commanders of the 

combatant commands (e.g., TRANSCOM). Communication from the Secretary of Defense 

to the commanders of the combatant commands is generally transmitted through the 

Chairman of the Joint Chiefs of Staff. See 10 U.S.C. § 163(a), (b); Department of Defense, 

Functions of the Department of Defense and Its Major Components, Directive 5100.01, 

para. 4.b(3)(b), (d) (Dec. 21, 2010).

and international standards for the transport of HAZMAT. To 

examine the extent to which DOD faces any challenges in implementing 

4

See Pub. L. No. 112-239, § 372 (2013).

5

Pub. L. No. 93-633, tit. I (1975) (codified as amended at 49 U.S.C. §§ 5101-5128).

6

The Hazardous Materials Regulations are located in parts 171-180 of Title 49 of the 

Code of Federal Regulations.

7

Department of Defense, Defense Transportation Regulation 4500.9-R, pt. II, “Cargo 

Movement,” 4500.9-R (Oct. 30, 2013). 

8

Department of Defense, Joint Chiefs of Staff, The Defense Transportation System, Joint 

Publication 4-01 (June 6, 2013).
Page 3 GAO-14-375 Defense Transportation

its policies and procedures for transporting HAZMAT in a safe, timely, and 

cost-effective manner, we selected and visited several DOD locations 

involved in transporting HAZMAT, including the U.S. Defense Supply and 

Distribution Center (Richmond, Virginia); Dover Air Force Base (Dover, 

Delaware); and Norfolk Naval Base (Norfolk, Virginia). We selected these 

locations because they provided a cross section of the various modes of 

transportation and hazardous-material classes. We focused our review on 

surface and air modes of transport—on surface transport because most 

individual shipments are transported by highway (94 percent in fiscal year 

2013) and on air transport because that mode generally has morerestrictive requirements (e.g., the quantity of certain HAZMAT like acetic 

acid, a class 8 HAZMAT, allowed on a passenger air transport is lower 

than other modes due to its corrosive properties). We reviewed data from 

TRANSCOM’s Global Air Transportation Execution System for 5 fiscal 

years (2009 through 2013) and Defense Transportation Tracking System 

records for 2 fiscal years (2012 and 2013) to analyze records related to 

pretransportation and transportation functions (e.g., handling, labeling, 

and packaging activities and the transport of HAZMAT in commerce to 

the final destination point), respectively.9

We conducted this performance audit from April 2013 to May 2014 in 

accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

We compared data from those 

records with requirements in the Defense Transportation Regulation and 

found that the data we examined were sufficiently reliable for the 

purposes of identifying challenges and the extent to which they affect the 

transport of HAZMAT. To corroborate our understanding of the 

documents and data we analyzed, we interviewed officials from the Office 

of the Secretary of Defense; the Office of the Deputy Assistant Secretary 

of Defense for Transportation Policy; the Defense Logistics Agency; the 

Army, the Air Force, the Navy, and the Marine Corps; and DOT’s Pipeline 

and Hazardous Materials Safety Administration. See appendix I for more 

information on our scope and methodology.

 9

Under the Hazardous Materials Regulations, transportation of HAZMAT in commerce 

begins when the carrier takes physical possession of the HAZMAT for the purpose of 

transporting it and continues until the package is delivered to the indicated destination. 

See § 171.1(c).
Page 4 GAO-14-375 Defense Transportation

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.

HAZMAT is any substance or material that the Secretary of 

Transportation has determined is capable of posing an unreasonable risk 

to health, safety, or property when transported in commerce. The 

Secretary of Transportation designates HAZMAT under the Hazardous 

Materials Transportation Act and its implementing regulations.10 Within 

the federal government, DOT has the primary responsibility to issue 

regulations for the safe transport of HAZMAT in intrastate, interstate, and 

foreign commerce.11

According to DOT’s Office of Hazardous Materials Safety, an estimated 

1.4 million HAZMAT shipments are transported in the United States each 

day on average. These shipments amount to more than 3 billion tons of 

HAZMAT transported every year. While only about 43 percent of all 

HAZMAT tonnage is transported by highway, that tonnage accounts for 

approximately 94 percent of the individual shipments. Air, water, rail, and 

pipeline constitute the remaining HAZMAT transportation modes, with air 

generally being the most restrictive (due to aircraft cargo limitations and 

load restrictions).

To accomplish this mission, DOT issues HAZMAT 

regulations and provides other services to the transportation community 

and emergency responders—such as training, enforcement, technical 

support, information, and policy guidance—to protect the public against 

the safety risks inherent in transporting HAZMAT.

DOT uses a United Nations classification system to categorize all 

HAZMAT into nine classes and ensure its safe storage, handling, 

transportation, use, and disposal. Each of the nine HAZMAT classes is 

defined by a specific set of parameters—usually characterized by 

chemical properties (e.g., an oxidizer material) or inherent physical 

properties (e.g., a corrosive material) or as possibly posing a health 

hazard (e.g., a poisonous substance). Figure 1 shows examples of DOT’s 

labels, warning labels, and hazard warnings for the nine classes of 

 10See 49 U.S.C. § 5103(a); 49 C.F.R. § 172.101.

11See § 5103(b); § 171.1.

Background

HAZMAT Overview and 

Role of the Department of 

Transportation (DOT)
Page 5 GAO-14-375 Defense Transportation

HAZMAT, which can be further subdivided into divisions (e.g., class 5 is 

divided into 5.1 and 5.2).12

Figure 1: Examples of the Department of Transportation’s (DOT) Labels for the Nine 

Classes of Hazardous Materials (HAZMAT)

For example, HAZMAT in these classes could include explosives, which 

are class 1; gasoline, class 3; and lithium batteries, class 9.13

TRANSCOM is DOD’s single manager for transportation, other than 

service-unique or theater-assigned assets.14

 12Fig. 1 provides examples of hazard warning labels for the nine hazard classes and does 

not include all relevant hazard warning labels.

The command is composed 

of three military service component commands that manage the 

movement of DOD shipments, including HAZMAT—the Army’s Military 

13The Hazardous Materials Regulations also classify certain materials as Other Regulated 

Material. This class includes materials which, although otherwise subject to the 

Regulations, present a limited hazard during transportation due to form, quantity, and 

packaging. See § 173.144.

14In this role, TRANSCOM is responsible for providing common-user and commercial air, 

land, and sea transportation, terminal management, and aerial refueling to support the 

global deployment, employment, and sustainment and redeployment of U.S. forces. 

TRANSCOM is also responsible for procuring commercial transportation services. See

Department of Defense, United States Transportation Command (USTRANSCOM), 

Directive 5158.04, para. 4.6.9 (July 27, 2007) (incorporating change Sept. 11, 2007). 

TRANSCOM also serves as the DOD Distribution Process Owner, responsible for 

overseeing the overall effectiveness, efficiency, and alignment of DOD-wide distribution 

activities. See id., para. 4.6.15.

DOD Management of 

HAZMAT Transportation
Page 6 GAO-14-375 Defense Transportation

Surface Deployment and Distribution Command, the Navy’s Military 

Sealift Command, and the Air Force’s Air Mobility Command. The Army’s 

Military Surface Deployment and Distribution Command provides 

worldwide common-use ocean terminal services and traffic-management 

services, conducts port operations at sealift terminals, and plans, 

transports, and tracks shipments transported by surface and rail. The 

Navy’s Military Sealift Command transports shipments over water using a 

mixture of government-owned and commercial ships. The Air Force’s Air

Mobility Command transports shipments to destinations anywhere around 

the world by military or commercial carriers by air and serves as the 

single port manager for common-user aerial ports.

DOD installations, bases, or sites appoint personnel to assist with trafficmanagement functions. These traffic-management functions include, but 

are not limited to, providing efficient, responsive, and quality 

transportation services. These duties also include assisting with the 

handling, labeling, and packaging of HAZMAT shipments prior to offering 

them to carriers for transport. Shipments may originate at a vendor (e.g., 

a manufacturer) or DOD location (e.g., a Defense Logistics Agency 

depot). Moreover, a manufacturer might use a separate commercial 

carrier than one used by DOD to deliver its parts to the DOD installation 

that ordered them.

Shippers, carriers, and receivers carry out the three basic roles of the 

transportation system. A shipper may be a DOD entity (e.g., the Defense 

Logistics Agency), or a contracted commercial vendor (e.g., a 

manufacturer) where a shipment originates. A carrier may be a DOD 

entity or a private-sector individual or company that transports shipments 

from the shipper to the receiver. A receiver is the DOD entity that is the 

final destination point for the shipment. In cases in which shipments are 

destined for overseas areas, the shipments may be transported through 

central receiving points, such as one of DOD’s five aerial ports or a 

Defense Logistics Agency depot, before being sent to the final destination 

point. In figure 2, we list the specific functions that a shipper, carrier, and 

receiver might perform to transport HAZMAT.
Page 7 GAO-14-375 Defense Transportation

Figure 2: Functions That a Shipper, Carrier, and Receiver Might Perform to Transport Hazardous Materials (HAZMAT) in 

Commerce

A shipper is responsible for performing several functions prior to the 

movement of HAZMAT. These pretransportation functions include, but 

are not limited to, the following:

• Determining the hazard class and mode of transportation: The shipper

reviews the Hazardous Materials Regulations to properly identify the 

hazardous materials in the shipment. This information is needed to 
Page 8 GAO-14-375 Defense Transportation

determine the packaging, marking, and labeling,15

• Packaging and labeling: Once the mode of transportation has been 

determined, the shipper selects the appropriate packaging and 

labeling, fills the package, secures a closure on the package, and 

affixes the appropriate labels.

and other 

requirements for the specific type of HAZMAT being transported.

• Documentation: HAZMAT shipments that require documentation (as 

shown in fig. 3 and fig. 4) must describe the HAZMAT and the total 

quantity of the HAZMAT being shipped, provide emergency response 

information, and provide certification by the shipper that the HAZMAT 

is in proper condition for transportation.

• Loading, blocking, and bracing: The HAZMAT package is to be 

appropriately loaded, blocked, and braced in a freight container or 

transport vehicle. During this process, the HAZMAT may be 

segregated in a transport vehicle to ensure that it is not transported 

with an incompatible shipment.

• Selecting, providing, or affixing placards: The container and the 

carrier’s vehicle are to be properly marked to identify that the vehicle 

contains HAZMAT.

 15For purposes of this report, we use the general phrase packaging and labeling to refer to 

a variety of pretransportation functions, including selecting, filling, securing, marking, and 

labeling HAZMAT packaging.
Page 9 GAO-14-375 Defense Transportation

Figure 3: Example of Hazardous Materials (HAZMAT) Documentation Used for 

Transporting Arms, Ammunition, and Explosives by Air (Shipper’s Declaration for 

Dangerous Goods)
Page 10 GAO-14-375 Defense Transportation

Figure 4: Example of Documentation and Packaging Used for Transporting a 

Biological Sample (HAZMAT Class 6)

Once a shipper has completed the required pretransportation functions, a 

carrier takes possession of the HAZMAT shipment and performs the 

transportation functions.16 Transportation functions include the 

movement, loading incidental to movement, unloading incidental to 

movement, and storage incidental to movement.17

 16Under the Hazardous Materials Regulations, transportation of HAZMAT in commerce 

begins when the carrier takes physical possession of the HAZMAT for the purpose of 

transporting it and continues until the package is delivered to the indicated destination.

See § 171.1(c).

Transport may involve 

a single mode of transport (e.g., by highway or aircraft) or it can be 

17See § 171.1(c)(1)-(4). Under the Hazardous Materials Regulations, loading incidental to 

movement includes loading packaged or containerized HAZMAT for the purpose of 

transportation when performed by carrier personnel or in the presence of carrier 

personnel. See § 171.1(c)(2). Unloading incidental to movement includes removing 

HAZMAT when performed by carrier personnel or in the presence of carrier personnel. 

See § 171.1(c)(3). Storage incidental to movement involves the storage of a transport 

vehicle, freight container, or package containing HAZMAT by any person between the 

time that a carrier takes physical possession of the HAZMAT for the purpose of 

transporting it until the package has been delivered to the indicated destination. It does 

not include storage of HAZMAT at its final destination. See § 171.1(c)(4).
Page 11 GAO-14-375 Defense Transportation

multimodal—for example, moving first by surface (by highway or rail) and 

then through a central receiving point, such as an aerial port (for aircraft) 

or a depot. At the end of the transportation function, a carrier delivers the 

HAZMAT shipment to its final destination point, where a receiver takes 

possession of the HAZMAT shipment for immediate use or storage for 

later use.18

When transporting HAZMAT, there is a complex framework of statutes 

and regulations prescribed by multiple civilian and military entities that 

must be considered and evaluated to ensure safe, secure, and efficient 

transport. The Hazardous Materials Transportation Act, enacted in 1975 

and since amended,19 is the primary statutory regime governing the 

transport of HAZMAT in the United States. The purpose of the act is to 

protect against the risks to life, property, and the environment that are 

inherent in the transport of HAZMAT in intrastate, interstate, and foreign 

commerce.20

 18The Hazardous Materials Regulations do not apply to unloading HAZMAT from a 

transport vehicle or bulk packaging performed by the recipient following delivery by the 

carrier and after the carrier has departed. The regulations also do not apply to storage of a 

freight container, transport vehicle, or package containing HAZMAT after delivery to the 

indicated destination. See § 171.1(d)(2), (3).

To implement the act, DOT issued the Hazardous Materials 

Regulations, located in Title 49 of the Code of Federal Regulations, which 

generally govern the handling, labeling, packaging, and transportation of 

19Pub. L. No. 93-633, tit. I (1975) (codified as amended at 49 U.S.C. §§ 5101-5128).

2049 U.S.C. § 5101.

The Handling, 

Labeling, and 

Packaging of DOD 

HAZMAT Shipments 

Is Governed by a 

Complex Framework 

of Statutes and 

Regulations

A Complex Framework of 

Statutes and Regulations 

Governs DOD’s Handling, 

Labeling, and Packaging 

of HAZMAT Shipments
Page 12 GAO-14-375 Defense Transportation

HAZMAT shipments in commerce, among other activities.21 The 

regulations include specific guidance pertaining to each of the nine 

classes of HAZMAT on the basis of their composition, level of danger, 

and mode of transport. With regard to DOD, the Defense Transportation 

Regulation prescribes how DOD is to transport HAZMAT. Specifically, the 

Defense Transportation Regulation incorporates or references 

requirements from DOT’s Hazardous Materials Regulations,22 as well as 

various international- and country-specific regulations or standards for 

transporting HAZMAT shipments by air and water.23

 21See generally 49 C.F.R. pts. 171-180.

In figure 5, we 

illustrate the statutory and regulatory elements that govern DOD’s 

handling, labeling, and packaging of HAZMAT shipments.

22The Hazardous Materials Regulations do not apply to the transport of HAZMAT in a 

motor vehicle, aircraft, or vessel operated by a federal, state, or local government 

employee solely for noncommercial federal, state, or local government purposes. § 

171.1(d)(5). However, through the Defense Transportation Regulation, DOD has generally 

applied the Hazardous Materials Regulations to shipments, whether conveyed by 

commercial or military carriers. See Department of Defense, Defense Transportation 

Regulation 4500.9-R, pt. II, ch. 204, Hazardous Materials, para. A.1 (Aug. 16, 2013). 

Section 173.7(b) of the Hazardous Materials Regulations also contains an exception for 

HAZMAT shipments made by or under the direction or supervision of the Department of 

Energy or DOD for the purpose of national security, subject to certain requirements. See § 

173.7(b). The Defense Transportation Regulation notes that this provision may only be 

used under a special program approved by a service or DOD component, service, or 

agency headquarters, and providing equal or better protection than the normal DOD, 

service, or DOT rules during transport. See Department of Defense, Defense 

Transportation Regulation 4500.9-R, pt. II, ch. 204, para. C.4.

23DOD guidance references International Air Transport Association, International Civil 

Aviation Organization, and International Maritime Organization technical instructions, 

codes, and regulations. The International Air Transport Association is the trade 

association for the world’s airlines, representing about 240 airlines, or 84 percent of total 

air traffic. The International Air Transport Association supports many areas of aviation 

activity and helps formulate industry policy on critical aviation issues. A specialized 

agency of the United Nations, the International Civil Aviation Organization was created in 

1944 to promote the safe and orderly development of international civil aviation throughout 

the world, among other objectives. It sets standards, recommended practices and 

procedures, and other guidance for aviation safety, security, efficiency, and regularity, as 

well as for aviation environmental protection. The organization serves as the forum for its 

191 member states regarding cooperation in all fields of civil aviation. The International 

Maritime Organization is a specialized agency of the United Nations with 170 member 

states, whose primary purpose is to develop and maintain a regulatory framework for 

shipping. The International Maritime Organization’s issues of concern include safety, the 

environment, legal matters, technical cooperation, maritime security, and efficiency.
Page 13 GAO-14-375 Defense Transportation

Figure 5: Existing Statutory and Regulatory Elements That DOD Incorporated into 

the Defense Transportation Regulation and Other Guidance

Applying the different regulations governing the transportation of a 

specific HAZMAT class to the mode of transportation can be complex for 

service transportation officials and requires careful reading of all 

applicable regulations. As an example, when shipping acetyl chloride 

(flammable liquid, class 3 HAZMAT) the shipper must review several 

sources to determine how to properly ship the item. If the shipper intends 

to ship the HAZMAT on a commercial aircraft carrying passengers, the 

Hazardous Materials Regulations indicate that no more than 1 liter of this 

liquid per package can be shipped because of the risk posed by 

transporting HAZMAT of that classification. If the HAZMAT is being 
Page 14 GAO-14-375 Defense Transportation

shipped by military aircraft or on an international flight, additional 

requirements and limitations may need to be applied. On the other hand, 

if carriers transport acetyl chloride by highway, they may be able to 

transport greater quantities.

DOD may also ship DOD-unique HAZMAT items that are not addressed 

in DOT’s Hazardous Materials Regulations or for which DOD needs to 

seek a waiver or approval. In these cases, the Hazardous Materials 

Regulations and DOT guidance specify a process that any commercial or 

government entity can use to apply for a DOT waiver in the form of a 

special permit or approval providing relief from requirements in the 

Hazardous Materials Regulations.24 DOD shipments may also use 

certificates of equivalence, which are approvals issued by DOD itself in 

instances where a packaging design differs from the requirements of the 

Hazardous Materials Regulations. Certificates of equivalence certify that 

the packaging equals or exceeds the comparable requirements of the 

Hazardous Materials Regulations.25 DOD shippers can use special 

permits or approvals from DOT or certificates of equivalence from DOD to 

handle department-unique HAZMAT shipments in a way commensurate 

with the DOT requirements.26

 24A special permit allows a person to perform a function not otherwise permitted under the 

Hazardous Materials Regulations. See § 107.1. An application for a special permit may be 

granted if it demonstrates, among other things, that the proposed alternative will achieve a 

level of safety that is at least equal to that required by the relevant regulation or, if the 

regulations do not establish a level of safety, is consistent with the public interest and 

adequately will protect against the risks to life and property inherent in transportation. See

§ 107.113(f)(2). In some instances, when required by regulation or international standard, 

DOD may alternatively need to seek a competent authority approval. As explained by 

DOD guidance, a competent authority approval is a written approval for specific HAZMAT 

which requires approval of the hazard classification or the packaging by a national 

competent authority prior to shipment. DOT is the competent authority for the United 

States. See Defense Transportation Regulation 4500.9-R, pt. II, ch. 204, para. H.1.b (Aug. 

16, 2013).

For example, according to officials, missiles 

transported in certain configurations are not standard items covered by 

the Hazardous Materials Regulations. Therefore, DOD obtained an 

25See, e.g., Defense Logistics Agency, Packaging of Hazardous Material, Directive 

4145.41 (Interservice), para. 4.14 (Oct. 22, 2007) (incorporating change Apr. 1, 2010) 

49 C.F.R. § 173.7(a).

26According to TRANSCOM officials, under most circumstances DOD at a minimum 

meets or exceeds the requirements contained in the Hazardous Materials Regulations and 

applies for waivers like other commercial shippers for HAZMAT items not specifically 

identified in the Hazardous Materials Regulations. 
Page 15 GAO-14-375 Defense Transportation

approval from DOT that indicates the type of packaging and container to 

be used to transport this item, which, according to officials, is equal to or 

exceeds the requirements of the Hazardous Materials Regulations. 

Similarly, for new items that are not mentioned in the Hazardous 

Materials Regulations, such as certain DOD-specific or emerging 

HAZMAT (e.g., lithium batteries with a metal casing) DOD might obtain a 

waiver that identifies how these items will be packaged and transported.

In addition to the statutory and regulatory elements discussed above, 

DOD has developed additional guidance to address specific 

circumstances that are either not covered in the existing framework of 

statutes and regulations or are areas where the department believes 

additional or different requirements are needed. For example:

• The Defense Transportation Regulation addresses the policies, 

procedures, and responsibilities for transporting HAZMAT by military 

aircraft.27 Additionally, Air Force Manual 24-204 (Interservice)

identifies procedural exceptions in the context of tactical, contingency, 

or emergency airlift.28

• For arms, ammunition, and explosives and certain classified 

shipments, the Defense Transportation Regulation contains 

requirements, procedures, and responsibilities related to the 

Transportation Protective Services program. Transportation Protective 

Services include a series of safeguards additional to those found in 

the Hazardous Materials Regulations such as, depending on the 

shipment, satellite tracking of the carrier vehicle using the Defense 

Transportation Tracking System and the use of two drivers with 

Because of the increased risk to the aircraft, 

aircrew, and participants, these procedural exceptions must only be 

used when there is a validated operational requirement. For example, 

in certain circumstances DOD may be able to use a single Shipper’s 

Declaration for Dangerous Goods to identify and certify more than one 

type of hazardous material when shipped under a single tracking 

number.

 27Policies, procedures, and responsibilities for transporting HAZMAT by military aircraft 

are identified in DOD guidance including Air Force Manual 24-204 (Interservice)/TM 38-

250/NAVSUP PUB 505/ MCO P4030.19J/DLAI 4145.3, Preparing Hazardous Materials for 

Military Air Shipments (Dec. 3, 2012) (hereinafter Air Force Manual 24-204 (Interservice))

and the Defense Transportation Regulation.

28See generally Air Force Manual 24-204 (Interservice), ch. 3.

DOD Has Developed 

Regulations and Other 

Guidance for 

Circumstances Unique to 

the Department
Page 16 GAO-14-375 Defense Transportation

security clearances to provide constant surveillance. TRANSCOM’s 

Surface Deployment and Distribution Command provides approval for 

certain commercial carriers to offer these Transportation Protective 

Services after determining that they meet safety performance 

thresholds, among other requirements.29

• According to Army health officials, the Defense Transportation 

Regulation also contains more-stringent training requirements for 

personnel shipping medical HAZMAT. As described by officials, the 

Defense Transportation Regulation and other guidance requires 

medical personnel who package and ship hazardous materials be 

trained and certified to do so at one of the DOD-approved hazardousmaterials transportation courses. Specifically, the Defense 

Transportation Regulation indicates that anyone involved with the 

transportation of pathogens or etiologic agents who manages, 

packages, certifies, or prepares laboratory samples and specimens or 

regulated medical waste for transport by any mode may satisfy the 

training requirement through specific courses offered by the Army 

Public Health Command.30 According to officials, these training 

requirements extend to those personnel who package and ship 

biological select agents and toxins as well.31

 29See Surface Deployment and Distribution Command, Military Freight Traffic Unified 

Rules Publication-1 (MFTURP-1) (June 3, 2013). 

30See Defense Transportation Regulation 4500.9-R, pt. II, ch. 204, para. D.1.d (Aug. 16, 

2013). An etiologic agent is a viable microorganism or its toxin that causes, or may cause, 

human disease.

31DOD guidance for safeguarding biological select agents and toxins states that, during 

the planning and preparation stages of off-station transportation of these agents and 

toxins, a current risk assessment shall be made including known threats and hazards. 

Planning for the move is to include appropriate security measures, and all reasonable 

precautions must be taken to ensure the safety and security of personnel and the agents 

and toxins. Department of Defense Instruction 5210.89, Minimum Security Standards for 

Safeguarding Biological Select Agents and Toxins, encl. 3, para. E3.7.5 (Apr. 18, 2006).
Page 17 GAO-14-375 Defense Transportation

According to TRANSCOM officials, in general DOD HAZMAT shipments 

arrive at their final destination without incident or delay; however, the 

department faces some challenges ensuring the safe, timely, and costeffective transportation of some HAZMAT shipments. According to DOD 

data, for HAZMAT transported by surface and air, improper 

documentation and packaging have led to transportation delays. In a 

limited number of instances with a potential for public safety and national 

security consequences, DOD installations did not provide carriers 

transporting sensitive arms, ammunition and explosives HAZMAT with 

access to secure hold areas or assist them in locating the nearest 

alternate means to secure those shipments. In addition, the reliability of 

safety performance data calls into question DOD’s process for selecting 

eligible, and evaluating current, HAZMAT carriers to transport arms, 

ammunition, explosives, and sensitive and classified shipments.

According to DOD information that we analyzed for air and surface 

HAZMAT shipments32 and according to officials, a substantial number of 

HAZMAT shipments were not documented and packaged in accordance 

with the Defense Transportation Regulation, which resulted in delays. To 

ensure the safe and secure transport of HAZMAT, DOD delayed the 

transport of these shipments until the documentation or packaging issues 

were resolved. According to agency officials we interviewed, these 

shipment delays can be as short as a few hours or last several weeks, 

depending on the nature of the issue. For example, regarding HAZMAT 

shipments to be transported by air, Global Air Transportation Execution 

System data show that, of the 246,747 total shipments of HAZMAT 

received at all five major domestic military aerial ports for fiscal years 

2009 through 2013, 67,149 shipments (or 27 percent) were delayed—

primarily because they were not in compliance with the Defense 

Transportation Regulation requirements for documentation and 

packaging.33

 32The DOD data that we reviewed did not contain shipments carried by small-package 

carriers.

While the Surface Deployment and Distribution Command 

33The Department of Defense uses the Global Air Transportation Execution System at 19 

aerial ports and 139 active remote and deployed sites worldwide to document the 

transport of shipments. The system also, among other things, supports the processing of 

those shipments, reports in-transit tracking data, and tracks the data necessary for billing 

to Air Mobility Command’s financial-management directorate.

DOD Has 

Experienced Some 

Challenges in 

Implementing 

HAZMAT Policies and 

Procedures, Which 

Can Adversely Affect 

the Safe, Timely, and 

Cost-Effective 

Transportation of 

HAZMAT

DOD HAZMAT Shipments 

Were Improperly 

Documented and 

Packaged
Page 18 GAO-14-375 Defense Transportation

data are not aggregated in the same format as the air shipment data, 

according to agency officials, improper documentation and packaging 

cause some delays in transportation of surface HAZMAT shipments. 

According to DOD officials, improper documentation and packaging also 

result in delays for the sea transportation mode.34

• Improper documentation (air): At a major aerial port we visited, we 

identified examples of HAZMAT shipments containing acetaldehyde 

(flammable liquid, class 3 HAZMAT) that were delayed because, 

according to officials, they were missing the Shipper’s Declaration for

Dangerous Goods. The Defense Transportation Regulation requires 

that when transporting HAZMAT by air, the shipper must complete a 

Shipper’s Declaration for Dangerous Goods for the shipment. In 

another example, at a depot we visited, we identified various 

HAZMAT shipments of lithium batteries that were also delayed 

because, according to officials, they had improper HAZMAT shipping 

names on the bill of lading.

Agency officials stated 

that the specific documentation and packaging issues that resulted in 

delays varied. Following are examples that illustrate the types of 

instances that we identified during the course of our review in which, 

according to officials, the documentation and packaging of HAZMAT 

shipments were not in compliance with the Defense Transportation 

Regulation requirements and resulted in delays:

• Improper documentation (surface): We found instances of similar 

documentation problems for surface transportation that led to 

HAZMAT transportation delays. Reviewing examples of 

Transportation Discrepancy Reports—which are used to document 

shipper-related discrepancies, among other things—we found that 

improper documentation is a major cause for delays. For example, in 

the reports we found instances where the required Dangerous Goods 

Declaration forms were missing and where the proper HAZMAT 

material name was not included with the shipment as required by the 

Defense Transportation Regulation.

• Improper packaging (air): At a major aerial port we visited, we 

identified a shipment of rusted acetylene (flammable gas, class 2.1 

HAZMAT) gas cylinders that were delayed in transport because, 

according to officials, they had arrived at the aerial port improperly 

packaged—stacked on top of one another in lidless wooden boxes 

 34Our review focused on freight motor (truck) surface and air transportation. Specific rail 

and sea ports data were not analyzed.
Page 19 GAO-14-375 Defense Transportation

(see fig. 6). According to military aerial port officials, to comply with 

the requirements of the Defense Transportation Regulation the rusted 

cylinders need to be recertified to ensure the integrity of the 

packaging before they are safe for air transport and may not be 

stacked on top of one another. Officials told us that, as a result of 

improper packaging, the potentially dangerous acetylene cylinders 

were delayed at the aerial port until the packaging discrepancies 

could be resolved by the shipper.

Figure 6: Shipment of Improperly Packaged, Rusted Acetylene Gas Cylinders 

Delayed in Transport

• Improper packaging (air): We observed a dented drum of flammable, 

toxic liquid (class 3 HAZMAT) that aerial port officials identified as 

improperly packaged under the Defense Transportation Regulation 

because of its potential to leak (see fig. 7). The military aerial port 

officials pointed out that, when transported by air, leaking HAZMAT 

drums can cause serious damage to DOD personnel and aircraft 

transporting them.
Page 20 GAO-14-375 Defense Transportation

• Improper packaging (surface): Similarly, reviewing samples of 

Transportation Discrepancy Reports, we found instances of improper 

packaging. For example, we found a report of a shipment of helium 

gas (nonflammable gas, class 2.2 HAZMAT) in a container that, 

according to the report, was not properly secured (blocked and 

braced) for shipment. Another report identified an instance where a 

grenade (explosive, class 1.1 HAZMAT) arrived inside an armored 

vehicle instead of proper packaging for an explosive. Additionally, we 

found a report of a bottled oxygen (nonflammable gas, class 2.2 

HAZMAT) shipment that arrived via highway improperly packaged for 

air shipment. According to the report, the material must be packed in 

a flame penetration and thermal-resistant package aboard an aircraft 

to prevent a potentially serious accident.

Figure 7: Shipment of Improperly Packaged Flammable, Toxic Liquid Delayed in 

Transport

During the course of our review, DOD officials pointed out several 

potential causes for these types of noncompliance. While the DOD 

officials we interviewed provided information about specific HAZMAT 

shipment delays, none stated a holistic understanding of the root causes 

resulting in HAZMAT transportation delays. Specifically we found the 

following:
Page 21 GAO-14-375 Defense Transportation

• DOD officials from a surface port we interviewed told us that some 

DOD personnel and commercial shippers lack experience and training 

on HAZMAT documentation and packaging. Additionally, at an aerial 

port, officials believed that some commercial shippers also lacked 

familiarity with DOD HAZMAT documentation and packaging 

requirements and some shippers did not have HAZMAT-certified 

personnel to ensure proper HAZMAT documentation and packaging.

• Aerial port officials told us that normal personnel rotations 

exacerbated training problems because experienced personnel 

regularly moved to other positions, leaving less-experienced 

personnel behind to document and package HAZMAT shipments.

• Aerial port officials also told us that shippers have limited incentives to 

comply with DOD regulations because the aerial port itself has no way 

to discipline shippers that regularly transported improperly 

documented or packaged HAZMAT shipments knowing that in some 

cases the aerial port would fix the shipment.

• At another aerial port and DOD installation we visited, officials 

reported that miscommunication among the shipper, carrier, or 

receiver (incorrect shipping address or modes of transportation 

needed to transport the shipment) causes delays for HAZMAT 

shipments.

Additionally, DOD officials at the surface and aerial ports we visited noted 

that they lacked the ability or authority to correct the root causes they 

suspected to be the source of delays. As a result, when a HAZMAT 

shipment arrives with improper packaging, DOD officials at these ports 

can either correct the problem themselves by repackaging the shipment 

or attempt to contact the shipper to correct the issue.

In 2008, the Office of the Deputy Assistant Secretary of Defense for 

Transportation Policy commissioned a study to address DOD’s 

unacceptable level of delayed HAZMAT shipments. According to the 

Frustrated Cargo Analysis Final Project Report, the study’s scope was to 

reduce the effect of these delays by first defining the scope of the 

problem, developing a consensus on root causes, and providing a datacentric solution to the problems. While the 2008 report had several 

findings that identified causes for delays, including improper 

documentation and packaging of HAZMAT at an aerial port and a 

distribution depot, DOD has not resolved the problems addressed in that 

report or followed up on those findings with a more-recent analysis of the 

root causes for the delays that the department continues to experience. 

Moreover, we visited one of the sites identified in the report and observed 

that the same causes for delays with regard to documentation and 
Page 22 GAO-14-375 Defense Transportation

packaging of HAZMAT persisted at that location. Additionally, we visited a 

different distribution depot and noted the same causes for delays.

According to the Office of Management and Budget’s Management’s 

Responsibility for Internal Control,35 federal agencies should establish or 

maintain internal control to achieve effective and efficient operations and 

compliance with applicable regulations—in this case, the Defense 

Transportation Regulation and related guidance. Moreover, federal 

internal control standards call for agency management officials to 

promptly evaluate findings from audits and other reviews showing 

deficiencies, determine proper actions in response to those findings and 

recommendations, and complete, within established time frames, all 

actions that correct or otherwise resolve the matters brought to 

management’s attention.36 However, DOD has not conducted a recent, 

holistic analysis to determine the root causes for the significant number of 

delays in HAZMAT shipments resulting from improper documentation and 

packaging. DOD officials acknowledged that they do not have this current 

information and agreed that it would be helpful in identifying and 

addressing issues causing delayed HAZMAT shipments. Without such 

information, DOD cannot adequately ensure compliance with the Defense 

Transportation Regulation. These delays have resulted in DOD’s 

committing resources—personnel, storage space, and packing 

materials—to ensure that the delayed cargo can ultimately be transported 

safely.

 35Office of Management and Budget, Management’s Responsibility for Internal Control, 

Circular No. A-123 (Dec. 21, 2004).

36GAO, Standards for Internal Control in the Federal Government, GAO/AIMD-00-21.3.1

(November 1999).
Page 23 GAO-14-375 Defense Transportation

According to reports from the Surface Deployment and Distribution 

Command Operations Center’s Defense Transportation Tracking System, 

DOD installations did not provide commercial carriers access to a secure 

hold area for at least 44 out of 70,891 sensitive arms, ammunition, and 

explosives shipments or did not assist carriers in finding alternative 

means to secure those shipments in fiscal years 2012 and 2013.37

According to the Defense Transportation Regulation, DOD installations 

are to assist commercial carriers transporting DOD shipments of arms, 

ammunition, and explosives by providing secure hold areas in the interest 

of public safety and national security, or routing them to the nearest 

location that has a secure hold area. If an installation cannot 

accommodate the vehicle, personnel at the installation are to assist the 

carrier in locating the nearest alternate DOD installation or contractor 

activity capable of providing a secure hold area. At DOD installations that 

provide a secure hold area, DOD guidance regarding the security of 

conventional arms, ammunition, and explosives provides that shipments 

arriving after normal working hours or during nondelivery hours are to be 

accepted by the installation and provided secure hold protection 

commensurate with the sensitivity category of the items.

Although these instances represent a relatively small percentage of the 

overall number of sensitive arms, ammunition, and explosives shipments, 

not providing secure hold for even a small percentage of these sensitive 

shipments poses a risk to public safety and to national security. While we 

found no evidence of severe incidents resulting from these instances 

where commercial carriers transporting sensitive HAZMAT were not 

provided access to secure hold areas, the potential high-risk 

consequences to public safety and national security of this type of failure

are significant. A secure hold area is a location designated for the 

temporary parking of carrier vehicles transporting DOD-owned arms, 

ammunition, and explosives and other sensitive material.

38

 37The Surface Deployment and Distribution Command only collects information on arms, 

ammunition, and explosives secure-hold access issues when the DOD installation or 

Transportation Protection Service carrier report them. According to officials, there are 

likely many other access issues that were not reported.

At DOD 

installations that cannot or choose not to provide secure holding areas, 

DOD personnel are to assist the carrier with routing to the nearest DOD 

38See Department of Defense, Physical Security of Sensitive Conventional Arms, 

Ammunition, and Explosives (AA&E), Manual 5100.76, encl. 10, para. 7.a (Apr. 17, 2012).

DOD Installations Have 

Not Secured Sensitive 

Arms, Ammunition, and 

Explosives Shipments 

Delivered by Highway in a 

Timely Manner
Page 24 GAO-14-375 Defense Transportation

location (or other approved location such as a carrier-owned facility) that 

can provide secure hold.

To determine which DOD installations have the ability to provide secure 

hold, shippers and carriers use the Transportation Facilities Guide. The 

Transportation Facilities Guide lists DOD installation information including 

those that offer secure hold areas and their hours of operation, among 

other things. DOD installations are required to update their Transportation 

Facilities Guide records immediately whenever critical operational 

changes are made, such as changes in operating hours or installations 

closures. Otherwise, installations update the guide on a semiannual basis 

if the installation is participating in the secure hold area program and 

annually if it is not. However, even with the tools DOD makes available to 

DOD personnel, shippers, and carriers, some carriers of arms, 

ammunition, and explosives shipments are not able to gain access to 

secure hold areas.

To find examples of instances where carriers were not provided secure

hold or assisted with finding alternate locations, we examined 

descriptions reported in DOD’s Defense Transportation Tracking System 

Emergency Response Reports. Following are examples of instances in 

which DOD installations did not provide access to a secure hold area to 

carriers transporting sensitive and classified HAZMAT:

• A commercial carrier (i.e., a truck) transporting a shipment of 

ammunition, explosives, and fireworks arrived at its final destination 

point after normal working hours and was denied access to the 

installation. DOD personnel at the final destination point directed the 

carrier to another DOD installation for secure hold, but no one at that 

installation answered the carrier’s calls requesting secure hold for the 

night. Despite the carrier’s efforts to inform DOD personnel of the 

security requirements for arms, ammunition, and explosives 

shipments, the carrier was denied secure hold for the shipment and 

spent the night in his truck with the shipment in an empty parking lot 

near the highway. According to the Defense Transportation 

Regulation, temporary parking for certain arms, ammunition, and 

explosive shipments should be conducted at DOD-approved or 

commercially owned secure holding facilities.

• A DOD installation denied a commercial carrier access to a secure 

hold area for a shipment of thousands of pounds of aircraft flares and 

directed the carrier to park at a nearby major retail store parking lot. 

DOD personnel told the Surface Deployment and Distribution 

Command Operations Center that they regularly send carriers arriving 
Page 25 GAO-14-375 Defense Transportation

after hours to this retail store or a nearby rest area. Parking arms, 

ammunition, and explosives at either location may be inconsistent 

with DOD guidance.

• DOD personnel at a secure hold installation instructed a commercial 

carrier of a small-arms and parts shipment to arrive before the 

installation closed because they would not accept after-hours 

shipments. Furthermore, DOD personnel explained that the 

installation was located in an unsafe neighborhood and advised the 

carrier to park in a safe public parking lot away from the installation if 

arriving after hours. Observing that the shipment would arrive after 

hours, the carrier decided to spend the night in his truck with the 

shipment parked at a public truck stop near the interstate highway. 

The Defense Transportation Regulation indicates that personnel at 

the DOD installation should assist the commercial carrier in identifying 

another location that could provide secure hold.

According to the Defense Transportation Regulation, when commercial 

carriers experience challenges gaining access to a secure hold area, the 

carrier or DOD installation personnel can contact the Surface Deployment 

and Distribution Command for assistance. According to officials, 

Operations Center personnel are to attempt to resolve the issue by 

referring to relevant regulations such as the Defense Transportation 

Regulation, DOD Manual 5100.76-M (Physical Security of Sensitive 

Conventional Arms, Ammunition, and Explosives), or rerouting the 

shipment to another DOD location that can provide secure hold for the 

shipment. However, if the installation and Operations Center personnel 

cannot resolve the issue and grant carriers access to the secure hold 

area, Operations Center personnel are to generate an Emergency 

Response Report to document the actions taken by both parties and store 

those reports in the Defense Transportation Tracking System. According 

to the Surface Deployment and Distribution Command officials, 

Operations Center personnel forward the Emergency Response Reports 

to military-service representatives through an ad hoc process. However, 

according to the officials, no further corrective action is required by those 

representatives. As an example, during our visit the Operations Center 

personnel demonstrated several examples of recent incidents where they 

generated an Emergency Response Report as a result of DOD 

installation personnel denying a carrier access to a secure hold area or 

not assisting them in locating the nearest alternate means to secure those 

shipments.

While the Surface Deployment and Distribution Command’s Emergency 

Response Reports document installation and carrier issues gaining 

access to secure hold areas at some DOD installations, according to 
Page 26 GAO-14-375 Defense Transportation

Surface Deployment and Distribution Command officials they lack 

authority to change or require corrective actions to installation access 

policies. According to these officials, such actions would be taken by the 

military services or individual installation commanders. However, officials 

told us that there is no process within the installations’ commands—which 

set installation access policies—that requires them to follow up on 

Emergency Response Reports to identify needed improvements or 

recommend any corresponding corrective action at installations identified 

in the reports. However, the Office of Management and Budget’s 

Management’s Responsibility for Internal Control provides that 

management is responsible for establishing and maintaining internal 

control to achieve objectives such as compliance with applicable laws and 

regulations. It further notes that agencies and individual federal managers 

must take systematic and proactive measures to, among other things, 

assess the adequacy of internal control in federal programs and 

operations, identify needed improvements, and take corresponding 

corrective action. Without such a process, DOD may not be able to 

minimize the time that sensitive arms, ammunition, and explosives 

shipments spend in public areas.

To ensure the safety and security of DOD’s shipments of sensitive arms, 

ammunition, explosives, and classified shipments, DOD established a 

Transportation Protective Services program as part of the Surface 

Deployment and Distribution Command. Among other requirements to 

participate in the program, commercial carriers providing certain services 

must meet safety performance thresholds defined in DOD guidance using 

scores from DOT’s Compliance, Safety, Accountability program, which is 

managed by DOT’s Federal Motor Carrier Safety Administration.39

 39See Surface Deployment and Distribution Command, Military Freight Traffic Unified 

Rules Publication-1 (MFTURP-1). The Defense Transportation Regulation notes that 

implementation of the Transportation Protective Services procedures for commercial 

carriers will be in accordance with the MFTURP-1.

Specifically, DOD uses the Federal Motor Carrier Safety Administration’s 

Safety Measurement System scores—one component of the Compliance, 

Safety, Accountability program—to determine which carriers are eligible 

to participate in the department’s Transportation Protective Services 

DOT Safety Measurement 

System Used by DOD to 

Evaluate Transportation 

Protective Service Carriers 

Lacks Sufficient 

Information to Reliably 

Compare Safety 

Performance Across 

Carriers
Page 27 GAO-14-375 Defense Transportation

program.40 The Safety Measurement System within the Compliance, 

Safety, Accountability program is a data-driven approach for identifying 

carriers at risk of presenting a safety hazard or causing a crash. Safety 

Measurement System data comprise information collected during 

roadside inspections and from reported crashes to calculate scores 

across seven categories that quantify a carrier’s safety performance 

relative to that of other carriers. Specifically, the categories are: unsafe 

driving, crash indicator, hours of service compliance, driver fitness, 

controlled substances/alcohol, vehicle maintenance, and HAZMAT 

compliance.41

DOT uses the Safety Measurement System scores to, among other 

things, establish safety performance thresholds for carriers. For example, 

for HAZMAT commercial carriers, DOT establishes a threshold score of 

60 or lower (lower scores are better) in each of three categories: unsafe 

driving, crash indicator, and hours-of-service compliance. DOT’s Federal 

Motor Carrier Safety Administration identifies carriers who score above 

the threshold as those posing the greatest safety risk. The Federal Motor 

Carrier Safety Administration can then intervene to focus on specific 

safety behaviors. The Federal Motor Carrier Safety Administration 

intervention actions include sending warning letters, conducting on- and 

off-site investigations, fines, or placing the carrier out of service.

The Federal Motor Carrier Safety Administration calculates 

violation rates in each of these categories for each commercial carrier 

and then compares these rates to other carriers.

DOD uses DOT’s Safety Measurement System scores to determine 

whether commercial carriers are eligible for transporting HAZMAT under 

the department’s Transportation Protective Services program. For all but 

 40As part of a limited request for exemption submitted to DOT from certain hours-ofservice rules, Surface Deployment and Distribution Command noted that it has instituted 

several technical and administrative controls to ensure the efficient transportation of cargo 

requiring protective services—including conducting review of carrier compliance 

requirements and procedures for moving HAZMAT; evaluating carrier authority to operate 

on U.S. roadways; evaluating carrier compliance with Federal Motor Carrier Safety 

Administration’s Compliance Safety Accountability program and Safety Measurement 

System standards; providing over-the-road vehicle surveillance; and inspecting carrier 

facilities and corporate headquarters for compliance with DOD and DOT standards. See

78 Fed. Reg. 64,265, 64,266 (Oct. 28, 2013).

41For each of the categories, information is based on state-reported data. For example, 

the Unsafe Driving category looks at driving violations like speeding or reckless driving. 

The crash indicator is based on the carrier’s crash history. Driver’s fitness looks at the 

drivers’ training, experience, and medical qualifications.
Page 28 GAO-14-375 Defense Transportation

one of the seven Safety Measurement System categories, DOD requires 

that commercial carriers seeking to provide certain Transportation 

Protective Services meet DOT’s established HAZMAT carrier thresholds. 

For compliance with the Safety Measurement System HAZMAT 

regulations category, however, DOT establishes a threshold score no 

higher than 80 for commercial carriers. In contrast, DOD requires a morestringent score of 75. At the time of our review, only 53 of the over 

400,000 commercial carriers in the United States had been selected to 

participate in the Transportation Protective Services program.

In February 2014,42 we found that the Federal Motor Carrier Safety 

Administration faces challenges in reliably assessing safety risk for the 

majority of carriers. Among other things, most carriers lack sufficient 

safety performance data to ensure that Federal Motor Carrier Safety 

Administration can reliably compare them with other carriers using Safety 

Measurement System scores. Basing an assessment of a carrier’s safety 

performance on limited data may misrepresent the safety status of 

carriers, particularly those without sufficient data from which to reliably 

draw such a conclusion. In addition, previous evaluations of the Safety 

Measurement System have focused on estimating the correlations 

between crash risk and regulatory violation rates and Safety 

Measurement System scores. These evaluations have found mixed 

evidence that Safety Measurement System scores predict crash risk with 

a high degree of precision for specific carriers or groups of carriers. As we 

found, according to the Federal Motor Carrier Safety Administration’s own 

methodology, the Safety Measurement System is intended to prioritize 

intervention resources, identify and monitor carrier safety problems, and 

support the safety fitness determination process.43

 42GAO, Federal Motor Carrier Safety: Modifying the Compliance, Safety, Accountability 

Program Would Improve the Ability to Identify High Risk Carriers, 

The Federal Motor 

Carrier Safety Administration also includes a disclaimer with the publicly 

released Safety Measurement System scores stating that the data are 

intended for agency and law-enforcement purposes, and readers should 

not draw safety conclusions about a carrier’s safety condition based on 

the Safety Measurement System score, but rather the carrier’s official 

safety rating. Due to ongoing litigation related to the Compliance, Safety, 

GAO-14-114 

(Washington, D.C.: Feb. 3, 2014).

43Carrier Safety Administration, Carrier Safety Measurement System Methodology, ver. 

3.0.1 (Revised August 2013).
Page 29 GAO-14-375 Defense Transportation

Accountability program and the publication of Safety Measurement 

System scores, we did not assess the potential effects or tradeoffs 

resulting from the display or any public use of these scores.

44 We

recommended that DOT improve the Compliance, Safety, Accountability 

program by revising the Safety Measurement System methodology to 

better account for limitations in drawing comparisons of safety 

performance information across carriers; and in doing so, conduct a 

formal analysis that specifically identifies, among other things, the 

limitations in the data used to calculate Safety Measurement System 

scores including variability in the carrier population and the quality and 

quantity of data available for carrier safety performance assessments. 

According to federal internal control standards, for an entity to run and 

control its operations, it must have relevant, reliable, and timely 

communications, including operational data.45

DOT agreed to consider our February 2014 recommendations, but 

expressed what it described as significant and substantive disagreements 

with some aspects of our analysis and conclusions. To the extent that 

DOT makes changes to the Safety Measurement System methodology, 

this could also affect how DOD uses the information to evaluate 

Transportation Protective Services carriers’ safety performance because 

of the underlying data reliability concerns with the Compliance, Safety, 

Accountability program’s Safety Measurement System data.

Program managers need 

operational data to determine whether they are meeting their agencies’

goals for accountability, and effective and efficient use of resources.

 44See Alliance for Safe, Efficient and Competitive Truck Transportation v. FMCSA, No. 12-

1305, D.C. Cir. (filed July 16, 2012; oral argument Sept. 10, 2013). The litigation has been 

brought against FMCSA by a number of motor carrier trade associations and challenges, 

among other things, the agency’s public disclosure of the Safety Measurement System

scores and its encouragement of the use of these public data to help make sound 

business judgments. The carriers have requested the court to order that the Safety 

Measurement System scores not be publicly available until alleged flaws in the 

methodology are addressed in the context of the planned rulemaking. Under GAO’s policy 

to avoid addressing the merits of matters pending in litigation, we did not assess these 

matters.

45GAO/AIMD-00-21.3.1
Page 30 GAO-14-375 Defense Transportation

The complex framework governing the handling, labeling, and packaging 

of DOD’s HAZMAT shipments exists to ensure the safe, timely, and costeffective handling of these materials, but its complexity creates 

challenges as shippers, carriers, and receivers implement the various 

statutes and regulations of that framework. The distributed nature of this 

framework—policies and procedures drawn from various organizations, 

varying by class of HAZMAT and mode of transportation, and executed 

by multiple players—creates conditions under which mistakes can be 

made, particularly regarding pre-transportation functions (e.g., packaging 

and labeling). While DOD has issued regulations and other guidance 

regarding the handling of HAZMAT, it lacks adequate internal controls to 

help ensure that its actions are consistent with those regulations and 

guidance. Furthermore, the department lacks a clear understanding of 

why these pre-transportation mistakes keep occurring. Absent a better 

understanding of the root causes for these mistakes, the department will 

be unable to identify corrective actions to better ensure the safe, timely, 

and cost-effective transportation of its HAZMAT shipments. Moreover, 

absent a department-wide process to identify necessary corrective action 

to ensure that DOD installations provide access to secure hold, there is 

no assurance that the installations will not repeatedly deny access to the 

secure hold area for HAZMAT shipments or fail to assist carriers in finding 

alternative means to secure those shipments. While the relative scale of 

these incidents is fairly small, the nature of HAZMAT shipments is such 

that the risk to public safety as well as the potential impact of cost and 

timeliness should be minimized to the greatest extent practicable. DOD 

uses Safety Measurement System scores to determine safety 

performance of its Transportation Protective Services carriers. However, 

both our February 2014 report and the Federal Motor Carrier Safety 

Administration state that these scores should not be used to draw safety 

conclusions about a carrier’s safety condition. As a result, DOD may be 

determining which carriers should be eligible for the Transportation 

Protective Services program using the Compliance, Safety, 

Accountability’s Safety Measurement System that, for many carriers, 

lacks sufficient information to reliably assess carriers’ safety performance.

Conclusions
Page 31 GAO-14-375 Defense Transportation

To improve DOD’s compliance with HAZMAT regulations and other 

guidance and potentially reduce shipment delays, we recommend that the 

Secretary of Defense, in coordination with the Chairman of the Joint 

Chiefs of Staff, direct the Under Secretary of Defense for Acquisition, 

Technology and Logistics, in collaboration with the military departments

and TRANSCOM, to identify the root causes of improper documentation 

and packaging of HAZMAT throughout the DOD transportation system, 

identify any needed corrective actions, and develop an action plan with 

associated milestones to implement those corrective actions.

To minimize the time sensitive arms, ammunition, and explosives 

shipments spend in public areas, we recommend that the Secretary of 

Defense, in coordination with the Chairman of the Joint Chiefs of Staff, 

direct the Secretaries of the military departments, in collaboration with 

TRANSCOM, to establish a process to identify and implement the 

necessary corrective actions to ensure that DOD installations identified by 

Surface Deployment and Distribution Command’s Emergency Response 

Reports provide secure hold for sensitive shipments or assist them in 

locating the nearest alternate means to secure those shipments.

To better ensure the safety and security of DOD’s shipments of sensitive 

arms, ammunition, and explosives, we recommend that the Secretary of 

Defense, in coordination with the Chairman of the Joint Chiefs of Staff, 

direct TRANSCOM to examine the data limitations of the DOT Federal 

Motor Carrier Safety Administration’s Safety Measurement System raised 

in our February 2014 report on modifying DOT’s Compliance, Safety, and 

Accountability program and determine what changes, if any, should be 

made to the process used by DOD to decide HAZMAT carrier eligibility 

and evaluate performance for the Transportation Protective Services 

program.

Recommendations for 

Executive Action
Page 32 GAO-14-375 Defense Transportation

We provided a draft of our report to DOD and DOT for review. In written 

comments, DOD partially concurred with our first recommendation and 

fully concurred with our second and third recommendations. DOD’s 

written comments are reprinted in their entirety in appendix II. DOD and 

DOT provided technical comments, which we have incorporated 

throughout our report as appropriate. 

DOD partially concurred with our first recommendation that the Secretary 

of Defense, in coordination with the Chairman of the Joint Chiefs of Staff, 

direct TRANSCOM, in collaboration with the Secretaries of the military 

departments, to identify the root causes of improper documentation and 

packaging of HAZMAT throughout the DOD transportation system, 

identify any needed corrective actions, and develop an action plan with 

associated milestones to implement those corrective actions. DOD 

agreed to conduct the analysis we recommended, but stated that the 

Under Secretary of Defense for Acquisition, Technology, and Logistics 

rather than TRANSCOM would lead this analysis. DOD explained that, 

because of the myriad of issues to be addressed, including training and 

Transportation and Supply Discrepancy Reports, the Under Secretary of 

Defense for Acquisition, Technology, and Logistics, not TRANSCOM, is 

the proper organization to lead this analysis. We agree and have 

amended our first recommendation accordingly. 

DOD concurred with our second recommendation that the Secretary of 

Defense, in coordination with the Chairman of the Joint Chiefs of Staff, 

direct the Secretaries of the military departments, in collaboration with 

TRANSCOM, to establish a process to identify and implement the 

necessary corrective actions to ensure that DOD installations identified by 

Surface Deployment and Distribution Command’s Emergency Response 

Reports provide secure hold for sensitive shipments or assist them in 

locating the nearest alternate means to secure those shipments. 

Specifically, DOD stated that the Under Secretary of Defense for 

Intelligence reissued Department of Defense Instruction 5100.76. DOD 

also noted that the Under Secretary of Defense for Acquisition, 

Technology and Logistics will work with the Under Secretary of Defense 

(Intelligence), TRANSCOM, and the military departments to develop 

corrective actions and operating methods geared toward eliminating 

secure-hold denials. We agree that these actions, if fully implemented, 

would address our recommendation.

DOD concurred with our third recommendation that the Secretary of 

Defense, in coordination with the Chairman of the Joint Chiefs of Staff, 

direct TRANSCOM to examine the data limitations of the DOT Federal 

Agency Comments 

and Our Evaluation
Page 33 GAO-14-375 Defense Transportation

Motor Carrier Safety Administration’s Safety Measurement System raised 

in our February 2014 report on modifying DOT’s Compliance, Safety, and 

Accountability program and determine what changes, if any, should be 

made to the process used by DOD to decide HAZMAT carrier eligibility 

and evaluate performance for the Transportation Protective Services 

program. However, DOD did not identify any specific steps it planned to 

take to address our recommendation.

We are sending copies of this report to the appropriate congressional 

committees and to the Secretary of Defense and the Secretary of 

Transportation. The report also is available at no charge on GAO’s 

website at http://www.gao.gov.

If you or your staff have any questions about this report, please contact 

me at (202) 512-5431 or russellc@gao.gov. Contact points for our Offices 

of Congressional Relations and Public Affairs may be found on the last 

page of this report. Key contributors to this report are listed in appendix 

III.

Cary Russell

Director

Defense Capabilities and Management
Page 34 GAO-14-375 Defense Transportation

List of Committees

The Honorable Carl Levin

Chairman

The Honorable James M. Inhofe

Ranking Member

Committee on Armed Services

United States Senate

The Honorable Jay Rockefeller

Chairman

The Honorable John Thune

Ranking Member

Committee on Commerce, Science, & Transportation

United States Senate

The Honorable Richard Durbin

Chairman

The Honorable Thad Cochran

Ranking Member

Subcommittee on Defense

Committee on Appropriations

United States Senate

The Honorable Howard P. “Buck” McKeon

Chairman

The Honorable Adam Smith

Ranking Member

Committee on Armed Services

House of Representatives

The Honorable Bill Shuster

Chairman

The Honorable Nick Rahall

Ranking Member

Committee on Transportation & Infrastructure

House of Representatives
Page 35 GAO-14-375 Defense Transportation

The Honorable Rodney Frelinghuysen

Chairman

The Honorable Pete Visclosky

Ranking Member

Subcommittee on Defense

Committee on Appropriations

House of Representatives
Appendix I: Scope and Methodology

Page 36 GAO-14-375 Defense Transportation

To examine the statutes, regulations, guidance, policies, and procedures 

that govern the Department of Defense’s (DOD) handling, labeling, and 

packaging of hazardous material (HAZMAT) shipments to support military 

operations, we reviewed the Hazardous Materials Transportation Act, as 

amended;1 regulations issued by the Department of Transportation 

(DOT), including the Hazardous Materials Regulation in Title 49 of the 

Code of Federal Regulations;2 relevant sections of DOD’s Defense 

Transportation Regulation, Joint Staff guidance, including Joint

Publication 4-01, The Defense Transportation System;3

To examine the extent to which DOD faces any challenges in 

implementing its policies and procedures for transporting HAZMAT in a 

safe, timely, and cost-effective manner, we selected and visited several 

DOD locations involved in the transport of HAZMAT, including the U.S. 

Defense Supply and Distribution Center (Richmond, Virginia); 

and international 

standards for the transport of HAZMAT. To better understand the 

statutes, regulations, guidance, policies, and procedures that govern 

DOD’s handling, labeling, and packaging of HAZMAT shipments to 

support military operations, several members of the audit team completed 

a 2-day DOD-sponsored course on HAZMAT that covered the abovementioned areas and passed a comprehensive exam at the end of the 

course demonstrating their understanding and knowledge of those topics. 

To corroborate our understanding of this framework, we interviewed 

officials from the Office of the Deputy Assistant Secretary of Defense for 

Transportation Policy, Office of the Deputy Assistant Secretary of 

Defense for Supply Chain Integration, the U.S. Transportation Command 

(TRANSCOM), and DOT’s Pipeline and Hazardous Materials Safety 

Administration. To understand DOD-specific requirements for transporting 

HAZMAT shipments, we reviewed DOT’s Hazardous Materials 

Regulations and DOD’s Defense Transportation Regulation and 

interviewed officials from TRANSCOM—specifically, officials from the 

Surface Deployment and Distribution Command, which is the Army 

service component command of TRANSCOM that plans, transports, and 

tracks DOD shipments.

 1

Pub. L. No. 93-633, tit. I (1975) (codified as amended at 49 U.S.C. §§ 5101-5128).

2

The Hazardous Materials Regulations are located in parts 171-180 of Title 49 of the 

Code of Federal Regulations.

3

Joint Chiefs of Staff, The Defense Transportation System, Joint Publication 4-01 (June 6, 

2013). 

Appendix I: Scope and Methodology
Appendix I: Scope and Methodology

Page 37 GAO-14-375 Defense Transportation

TRANSCOM’s Surface Deployment and Distribution Command; and two 

of DOD’s five major aerial ports: Dover Air Force Base (Dover, Delaware) 

and Norfolk Naval Base (Norfolk, Virginia). Additionally, we interviewed 

officials from another major aerial port—Travis Air Force Base (Fairfield, 

California). We also visited Aberdeen Proving Ground (Aberdeen, 

Maryland) to review the transport of arms, ammunitions, and explosives, 

and to visit a secure hold location for that type of HAZMAT. We selected 

these locations because they provided a cross section of the various 

modes of transportation and hazardous-material classes. We also 

selected these locations because they provided us with information on the 

various central locations through which DOD transports these materials. 

We focused our review on surface and air modes of transport—on 

surface transport because most individual shipments are transported by 

highway (94 percent of all shipments in fiscal year 2013) and on air 

transport because that mode generally has more-restrictive requirements, 

for example the quantity of certain HAZMAT (like acetic acid, class 8 

HAZMAT) allowed on passenger air transport is lower than in other 

modes. We reviewed data from TRANSCOM’s Global Air Transportation 

Execution System for 5 fiscal years (fiscal years 2009 through 2013) and 

the Defense Transportation Tracking System for fiscal years 2012 and 

2013 to analyze records related to pretransportation and transportation 

functions (e.g., handling, labeling, and packaging activities and the 

transport of HAZMAT in commerce to the final destination point), 

respectively. We compared data from those records with requirements in 

the Defense Transportation Regulation. We found that the data we 

examined were sufficiently reliable for identifying challenges and the 

extent to which they affect the transport of HAZMAT.

We examined sections of the Hazardous Materials Regulations and the 

Defense Transportation Regulation related to documenting and 

packaging HAZMAT and to ensuring the secure hold of sensitive and 

high-risk HAZMAT at DOD installations. We compared those sections 

with records we examined related to pretransportation and transportation 

functions (e.g., handling, labeling, and packaging activities and the 

transport of HAZMAT in commerce to the final destination point). 

Specifically, we reviewed fiscal years 2009 to 2013 records from 

TRANSCOM’s Air Mobility Command’s Global Air Transportation 

Execution System database, which is the aerial port operations and 

management information system designed to support automated 

shipments and passenger processing. We also reviewed data from fiscal 

year 2012 and 2013 from the Emergency Response Reports provided 

from the Defense Transportation Tracking System, part of TRANSCOM’s 

Surface Deployment and Distribution Command, which catalogs 
Appendix I: Scope and Methodology

Page 38 GAO-14-375 Defense Transportation

information involving shipments of arms, ammunition and explosives, and 

other sensitive cargo. We found that the data we examined were 

sufficiently reliable to identify secure-hold access issues that had been 

reported. We reviewed records from DOT’s Federal Motor Carrier Safety 

Administration to understand the Compliance Safety and Accountability 

systems and how the safety scores generated by the system are used to 

evaluate the Transportation Protective Services’ 53 carriers that transport 

DOD’s sensitive arms, ammunition, and explosives shipments. To 

corroborate our understanding of the documents and data we analyzed, 

we interviewed officials from the Office of the Secretary of Defense; the 

Office of the Deputy Assistant Secretary of Defense for Transportation 

Policy; the Defense Logistics Agency; the Army, the Air Force, the Navy, 

the Marine Corps; and DOT’s Pipeline and Hazardous Materials Safety 

Administration.

We visited or contacted officials from the following DOD and DOT 

organizations during our review:

• Defense Logistics Agency, Aviation Branch, Richmond, Virginia;

• Defense Logistics Agency, U.S. Defense Supply and Distribution 

Center, Richmond, Virginia;

• Headquarters, Defense Logistics Agency, Fort Belvoir, Virginia;

• Headquarters, Department of the Army, Pentagon, Arlington, Virginia;

• Headquarters, U.S. Marine Corps, Naval Annex, Arlington, Virginia;

• Office of the Under Secretary of Defense (Acquisition, Technology 

and Logistics), Office of the Deputy Assistant Secretary of Defense 

(Transportation Policy), Mark Center, Alexandria, Virginia;

• Office of the Under Secretary of Defense (Acquisition, Technology 

and Logistics), Office of the Deputy Assistant Secretary of Defense 

(Supply Chain Integration), Mark Center, Alexandria, Virginia;

• U.S. Air Force, Dover Air Force Base, Dover, Delaware;

• U.S. Air Force, Travis Air Force Base, Fairfield, California;

• U.S. Air Force, Headquarters Air Materiel Command, WrightPatterson Air Force Base, Dayton, Ohio;

• U.S. Army Operations Center, Pentagon, Arlington, Virginia;

• U.S. Army, Public Health Command, Army Institute of Public Health, 

Aberdeen Proving Ground, Maryland;

• U.S. Army, Surface Deployment and Distribution Command, 596th 

Transportation Brigade, Sunny Point, North Carolina;

• U.S. Army, Surface Deployment and Distribution Command, 597th 

Transportation Brigade, Fort Eustis, Virginia;

• U.S. Army Sustainment Command, Rock Island Arsenal, Rock Island, 

Illinois;
Appendix I: Scope and Methodology

Page 39 GAO-14-375 Defense Transportation

• U.S. Army Medical Command, Fort Sam Houston, San Antonio, 

Texas;

• U.S. Army, Medical Research Institute of Chemical Defense, 

Aberdeen Proving Ground, Aberdeen, Maryland;

• U.S. Navy, Naval Station Norfolk, Norfolk, Virginia;

• U.S. Transportation Command, Scott Air Force Base, Illinois;

• Air Mobility Command;

• Military Sealift Command;

• Surface Deployment and Distribution Command;

o Defense Transportation Tracking System Office; and

• U.S. Department of Transportation, Washington, D.C.

We conducted this performance audit from April 2013 to May 2014 in 

accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.
Appendix II: Comments from the Department 

of Defense

Page 40 GAO-14-375 Defense Transportation

Appendix II: Comments from the Department 

of Defense
Appendix II: Comments from the Department 

of Defense

Page 41 GAO-14-375 Defense Transportation
Appendix II: Comments from the Department 

of Defense

Page 42 GAO-14-375 Defense Transportation
Appendix III: GAO Contact and Staff 

Acknowledgments

Page 43 GAO-14-375 Defense Transportation

Cary Russell, (202) 512-5431 or russellc@gao.gov

In addition to the contact named above, James A. Reynolds, Assistant 

Director; Adam Anguiano; Alfonso Garcia; Brandon Jones; Mae Jones; 

Oscar W. Mardis; Terry Richardson; and Michael Shaughnessy made key 

contributions to this report.

Appendix III: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments

(351811)
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