IG-00-004

AUDIT

REPORT MANAGEMENT AND ADMINISTRATION OF

INTERNATIONAL AGREEMENTS AT NASA

January 14, 2000

National Aeronautics and

 Space Administration

OFFICE OF INSPECTOR GENERAL

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Acronyms

CBSC China Broadcasting Satellite Corporation

FMM Financial Management Manual

GAO General Accounting Office

ISS International Space Station

NPD NASA Policy Directive

NPG NASA Procedures and Guidelines
W January 14, 2000

TO: A/Administrator

FROM: W/Inspector General

SUBJECT: INFORMATION: Management and Administration of

 International Agreements

 Report Number IG-00-004

The NASA Office of Inspector General has completed an audit of Management and

Administration of International Agreements. We found that controls are generally adequate to

ensure international agreements are appropriately executed and monitored. However,

documentation and information related to the international agreements were not complete or

accurate. As a result, the Agency is relying on incomplete and inaccurate information when

drafting new international agreements or responding to inquiries. In addition, the Agency has

held a deposit of about $200,000 from a foreign government corporation for more than 15 years

for launches of two satellites that never occurred. The Agency may not be entitled to the funds.

Background

The Space Act permits NASA to enter into agreements with other U.S. entities, state and local

governments, institutions and foreign governments to accomplish its mission. The NASA Office

of External Relations is responsible for developing and implementing Agency international

policies, including drafting, coordinating, negotiating and maintaining records on all international

agreements, and for ensuring that Agency programs are conducted in accordance with

Administration and Agency international policies. As of May 1999, NASA had about 3,200

nonreimbursable and 300 reimbursable international agreements. The Office of External

Relations, NASA Headquarters, maintains a library of copies of NASA’s international

agreements on-site at to support daily management operations. Original agreements are

maintained off-site in permanent record storage and are not readily available. The Office of

External Relations also maintains a computer based database of NASA’s agreements to facilitate

identifying agreements, responding to inquiries, reporting, and to support daily operations.
2

Recommendations

We recommended that the Associate Administrator for External Relations (1) establish controls

to ensure the completeness and accuracy of documentation and information in the

international agreements library and database. We also recommended that the Chief Financial

Officer (2) promptly review and dispose of the funds in the foreign deposit account and (3)

identify and review other reimbursable international agreement accounts with no recent cost

activity.

Management Response and OIG Evaluation

Management concurred with the findings and recommendations. The Associate Administrator

for External Relations is designating a new International Agreements Database Administrator

and is identifying agreements concluded in recent years but not entered into the database. The

Office of External Relations is acquiring a document scanner to maintain the international

agreements library in an electronic format. Further, the Chief Financial Officer has transferred

the foreign deposit to the U.S. Treasury as miscellaneous receipts and is reviewing other accounts

to determine the appropriateness of deposit retention. The Chief Financial Officer anticipates

completion of this review in March 2000.

We consider two of the three recommendations dispositioned and closed for reporting purposes.

We are monitoring recommendation three concerning identification of other reimbursable

accounts with no recent cost activity for reporting purposes pending implementation of agreed-to

corrective actions.

[original signed by]

Roberta L. Gross

Enclosure

Final Report on Audit of Management and Administration of

 International Agreements at NASA
FINAL REPORT

AUDIT OF MANAGEMENT AND ADMINISTRATION OF

INTERNATIONAL AGREEMENTS AT NASA
W January 14, 2000

TO: B/Chief Financial Officer

I/Associate Administrator for External Relations

FROM: W/Assistant Inspector General for Auditing

SUBJECT: Final Report on the Audit of Management and Administration of

International Agreements at NASA

Assignment Number A9903600

Report Number IG-00-004

The subject final report is provided for your use. Please refer to the Executive Summary for the

overall audit results. Our evaluation of your response is incorporated into the body of the report. The

corrective actions completed on recommendations one and two were responsive, and those

recommendations are considered closed for reporting purposes. Recommendation three will remain

open for reporting purposes pending implementation of agreed-to corrective actions. Please notify us

when action has been completed on recommendation three, including the extent of testing performed

to ensure corrective actions are effective.

If you have questions concerning the report, please contact Mr. Kevin J. Carson, Program

Director, Safety and Technology Audits, at (301) 286-0498, or Mr. William A. Garay, Auditorin-Charge, at (301) 286-9076. We appreciate the courtesies extended to the audit staff. See

Appendix D for the report distribution.

[original signed by]

Russell A. Rau

Enclosure
cc:

B/Comptroller

BF/Director, Financial Management Division

G/General Counsel

JM/Director, Management Assessment Division
bcc:

B/Audit Liaison Representative

IM/Audit Liaison Representative

W/GSFC/K. Carson

 W. Garay

 D. Choma
Contents

Executive Summary, i

Introduction, 1

Findings and Recommendations, 2

Finding A. International Agreements Documentation and Records, 2

Finding B. Retention of Foreign Launch Deposit, 6

Appendix A - Objectives, Scope, and Methodology, 9

Appendix B - NASA News Release, 11

Appendix C - Management’s Response, 12

Appendix D - Report Distribution, 16
NASA Office of Inspector General

IG-00-004 January 14, 2000

 A9903600

Management and Administration of International Agreements at NASA

Executive Summary

Background. The National Aeronautics and Space Act of 1958 (Space Act) permits the

NASA Administrator to engage in international cooperative programs pursuant to the

Agency’s mission. An International Space Act Agreement (international agreement) is an

agreement in which one or more of the partners is not a U. S. citizen or entity.

International agreements are formal written commitments of NASA resources to a

cooperative project and depending upon the significance of the agreement, are signed by

the President, Secretary of State, the NASA Administrator, or the Associate Administrator

for External Relations. An agreement is typically for scientific research that may take from

6 months to 30 years to complete. As of May 1999, NASA had about 3,200

nonreimbursable and 300 reimbursable international agreements.1

 The Office of External

Relations is functionally responsible for management of NASA’s international agreements.

Objectives. The overall objective of the audit was to determine whether NASA’s

management of international agreements is adequate. Our objective related to this report

was to determine whether international agreements were appropriately executed and

monitored.

Appendix A contains further details on the audit objectives, scope, and methodology.

Results of Audit. Controls are generally adequate to ensure international agreements are

appropriately executed and monitored. However, documentation and information related

to the international agreements were not complete or accurate. As a result, the Agency is

relying on incomplete and inaccurate information when drafting new international

agreements or responding to inquiries (see Finding A). In addition, the Agency has held a

deposit of about $200,000 from a foreign government corporation for more than 15 years

for launches of two satellites that never occurred. The Agency may not be entitled to the

funds (see Finding B).

 

1

 As of May 1999, the Office of External Relations was able to identify 3,200 nonreimbursable (no exchange

of funds between the partners) agreements since NASA’s inception, but could not readily identify those that

are currently active. Additionally, the Office of the Chief Financial Officer identified 300 active reimbursable

(payments to NASA for goods or services supplied) agreements, but could not identify the total number

completed since NASA’s inception.
ii

Summary of Recommendations. We recommend that NASA management establish

controls to ensure the completeness and accuracy of documentation and information in the

international agreements library and database, promptly review and disposition the funds in

the foreign deposit account, and identify other reimbursable accounts with no recent cost

activity.

Management’s Response. Management concurred with each recommendation. The

complete text of the response is in Appendix C. We consider management’s comments

responsive.
Introduction

The Space Act grants NASA broad discretion in the performance of its functions. The

Space Act further permits the Agency to enter into agreements with other U.S. entities,

state and local governments, educational institutions, and foreign governments to

accomplish its mission. An “agreement” defined in the broadest context, includes any

agreement concluded under the authority of the Space Act (contracts, leases, cooperative

agreements, or other transactions). Agreements generally establish a set of legally

enforceable promises between NASA and another party to the agreement, requiring

commitment of NASA resources to accomplish the objectives of the agreement. An

international agreement may include nonreimbursable (no funds exchanged) or

reimbursable terms.

NASA’s Enterprises are responsible for identifying and competitively selecting scientific

and technical proposals leading to the initiation of international agreements for any

selected participation in NASA’s programs. The NASA Headquarters Office of External

Relations directs Agency international relations, including coordinating with foreign

entities, serving as NASA’s liaison with the Department of State, and ensuring programs

are implemented in accordance with Administration and Agency international policies. A

substantive role of the Office of External Relations is supporting NASA’s Enterprises by

drafting and negotiating international agreements.
2

Findings and Recommendations

Finding A. International Agreements Documentation and Records

The Office of External Relations does not have complete or accurate information on the

Agency’s international agreements. Specifically, the Office of External Relations did not

maintain copies of all agreements and did not ensure that the database of agreements

contained accurate information. This condition exists because management controls over

access to records and data input were either not implemented or not followed. As a result, the

Office of External Relations is relying on incomplete and inaccurate information when using

existing agreements or the database for drafting new international agreements or when

responding to inquiries from other Federal agencies, Congress, foreign entities, or the public.

NASA Requirements Related to International Agreements

NASA Procedures and Guidelines (NPG) 1050.1, “Space Act Agreements Manual,” 

December 30, 1998, states that NASA has a statutory mandate to conduct its aeronautical and

space activities in cooperation with other nations. NASA’s foreign cooperative partners

typically are foreign governments, government agencies, or international organizations. Any

agreement with a foreign entity should be executed well in advance of the commencement of

significant joint activities. Otherwise, NASA assumes unnecessary legal risk if project

activities, such as exchange of detailed technical data or equipment or use of each party’s

facilities, take place without a legally binding agreement in place to appropriately allocate risk

of loss or damage and to impose conditions on treatment and use of technical data. NASA

Policy Directive (NPD) 1050.1F, “Authority to Enter into Space Act Agreements,”

November 13, 1998, assigns responsibility to the Associate Administrator for External

Relations for negotiating, executing, amending, extending, and terminating international

agreements.

NPD 1440.6E, “NASA Records Management,” April 29, 1997, contains guidance for all

NASA entities to follow to ensure Agency records are maintained in accordance with

applicable Federal policies and procedures. The NPD states:

It is NASA policy to accurately and completely make and preserve records

that contain documentation of the organization, functions, policies, decisions,

procedures, and essential transactions that are designed to furnish the

information necessary to protect the legal and financial rights of the

Government and of persons directly affected by the Agency’s activities,

preserve institutional memory, and permit NASA to be responsive to

Congress and oversight agencies.

International Agreements Library and Database Discrepancies

Significant discrepancies exist between the international agreements library and database,

which are both maintained by the Office of External Relations. The library did not contain

copies of agreements that the database indicated were on file. In contrast, the library
3

contained copies of agreements that the database indicated were not on file. The Office of

External Relations library and database manager stated that all agreements identified in the

database should be present in the library and that all agreements in the library should be

identified in the database. To test the accuracy of the database, we selected a judgmental

sample of 812 international agreements from a total of 3,202 NASA international agreements

recorded as of April 8, 1999. The sample represented those international agreements

approved from January 1, 1990, through March 24, 1999.

We identified discrepancies in the database for 163 (about 20 percent) of the 812 agreements

sampled. For example, the database indicated that copies of 673 of the 812 agreements were

on file in the library. However, the library did not contain copies of 147 of the 673

agreements that records in the database showed were on file. The database also indicated that

copies of 139 of the 812 agreements were not available in the library. Copies of 16 of the 139

agreements were in the library. Based on our sample results, the international agreements

library is incomplete and information in the international agreements database is often

inaccurate.

The incompleteness and inaccuracy of the international agreements library and database are

further evidenced by the absence of agreements related to the International Space Station

(ISS). The ISS is one of NASA’s most significant international programs and includes the

participation of numerous foreign countries. Although agreements between each of the

international partners and NASA were signed on January 29, 1998, copies are not in the

library and are not recorded in the database.

Factors Contributing to Discrepancies

Information on international agreements maintained in the library and database is incomplete

and inaccurate because management controls were either not implemented or not followed.

The library of international agreements is in an open and easily accessible area of the Office of

External Relations at NASA Headquarters where the agreements can be taken by anyone. The

Office of External Relations does not use basic controls such as a document sign-out system

that would establish accountability when an agreement is taken.

The accuracy of information in the database is dependent on the timely input of details into

the database on all new agreements as they are executed. The Office of External Relations

recently established a requirement that one individual in each division office is responsible for

inputting information on all new agreements. Additional management emphasis on updating

existing information in the database will help ensure that complete and accurate information is

readily available for all of NASA’s international agreements.

Need for Complete and Accurate Information

The library and database of international agreements are important resources used by the

Office of External Relations. In addition, Center personnel involved in international programs

and projects informed us that they were dependent on the Office of External Relations to
4

maintain permanent copies of their respective agreements. The office utilizes this information

to assist in its mission of coordinating NASA’s international policies and programs with other

Federal agencies, Congress, foreign entities, and the public. To illustrate, the House of

Representatives Committee on Science asked the General Accounting Office (GAO) to

provide information on the U.S. government’s international science and technology

agreements that support and encourage international cooperation in research and development.

The GAO report entitled “Federal Research, Information on International Science and

Technology Agreements,” April 1999, provides information on international agreements from

seven agencies including NASA. The GAO report states that information provided by NASA

was limited in scope because the Agency could not easily identify its total universe of active

agreements. NASA relied on the international agreements database as a source of information

in responding to the inquiry. A complete and accurate library and database would allow the

Office of External Relations to readily provide information on international agreements in

response to these types of inquiries.

Additionally, the Office of External Relations uses the information in the library and database

as reference material when preparing and negotiating new international agreements. The

introduction section of a new, successor, implementing, or related-subject agreement often

cites prior agreements with the same country. Copies of all agreements should also be

maintained in order for the Agency to ensure compliance with the agreements’ provisions,

which are generally governed by international law.

Recommendation for Corrective Action

The Associate Administrator for External Relations should:

1. Establish controls to ensure that copies of all international agreements are maintained in

the library and that information in the database is complete and accurate.

Management’s Response

Concur. Management is designating a new International Agreements Database Administrator

and is identifying agreements concluded in recent years but not entered into the database.

Management has included the database activity within the International Organization for

Standardization 9001 Headquarters Office Work Instruction “Formulation and Approval for

International Space Act Agreements.” Management also clarified that the library contains

working copies of NASA’s agreements and that originals are maintained in permanent

storage. The Office of External Relations is acquiring a document scanner and will maintain

the library of working copies of agreements in an electronic format. The complete text of the

comments is in Appendix C.
5

Evaluation of Management’s Response

The actions taken by management are responsive to the recommendation. We consider the

actions sufficient to disposition the recommendation, which will be closed for reporting

purposes.
6

Finding B. Retention of Foreign Launch Deposit

NASA continues to retain funds on deposit for reimbursable services that were not rendered.

Specifically, NASA received a deposit of about $200,000 in 1984 from a foreign government

corporation for Space Shuttle launch services that were never provided. The deposit is being

retained because the Office of the Chief Financial Officer has not reviewed the NASA

reimbursable account on a regular basis. Consequently, there has been no determination on

whether the Agency is entitled to the funds it has retained for more than 15 years.

NASA Financial Management Manual Requirements

The NASA Financial Management Manual (FMM), Chapter 9090, “Reimbursable and Other

Customer Agreements,” establishes financial management policies related to entering into

reimbursable and other customer agreements. The FMM defines a reimbursable agreement as

a binding agreement with customers for NASA to sell or rent materials, equipment, or

services. The FMM further provides that NASA will not initiate work or services or incur

reimbursable obligations until reimbursable agreements are signed and reimbursable funds are

available.

The FMM assigns responsibility to Enterprises or Functional Offices for preparing, approving,

monitoring, reviewing, and terminating Headquarters-negotiated, reimbursable agreements.

The NASA Headquarters Office of the Chief Financial Officer, Accounting, Reporting and

Analysis Branch is responsible for reviewing and concurring on Headquarters-negotiated,

reimbursable agreements and for maintaining financial records and related reports. The

Headquarters Financial Management Division is responsible for sending the final billing

statement to the reimbursable customer within 1 year of completion of the agreement.

Earnest Money Deposit for Launch Services

NASA continues to retain funds on deposit for launch services that were never provided. In

October 1984, NASA received an earnest money deposit of $199,985 from the China

Broadcasting Satellite Corporation (CBSC) for the planned (January and September) 1988

launches of two direct broadcast satellites from the Space Shuttle (see Appendix B). The

deposit was recorded in the Agency’s accounting records in Headquarters deposit account

80X6555, “Advances Received from Reimbursable Customers (Central Office).” The

Reimbursable Agreement Numbers of 1453-001-00-A and 00-B were established for the

services to be provided. A Request for Flight Assignment (STS Form 100), signed by the

president of the CBSC, accompanied the earnest money deposit.

The Agency has retained the deposit, even though NASA never provided launch services to

the CBSC. Personnel in the NASA Headquarters Office of Space Flight confirmed that the

launches never occurred and that they are not scheduled. Our review of accounting records

further verified that no costs were recorded against either of the reimbursable agreement

numbers.
7

Events Affecting Provision of Launch Services

Several events occurred after receipt of the earnest money deposit that could have precluded

NASA from providing the launch services to the CBSC. In April 1985, NASA became aware

that the CBSC intended to establish firm launch dates only after a spacecraft supplier had been

selected. The Office of Space Flight planned that a formal launch services agreement would

be completed after the spacecraft supplier was selected and the launch requirements were

known. NASA notified the CBSC that the January 1988 launch date could be rescheduled to

a later date since a spacecraft supplier had not yet been selected. The January 1986 explosion

of the Space Shuttle Challenger during take-off resulted in a revised NASA policy with

respect to commercial satellite launches. Specifically, the Agency directed that payloads that

can be launched on expendable launch vehicles could fly on the Shuttle only under

“compelling circumstances.” There is no record of official contact between NASA and the

CBSC subsequent to these events.

Personnel in the Office of Space Flight stated that during the 1984 period, the Office of Space

Flight had informed Space Shuttle customers that earnest money deposits for launches were

nonrefundable. Documentation was not available for us to determine whether the CBSC had

been advised of or agreed to these terms. Office of Space Flight personnel also stated that

NASA may be entitled to some portion of the deposit on the basis that administrative costs

were probably incurred and chargeable. However, Office of Space Flight personnel did not

have documentation supporting any costs, nor were any recorded in the Agency’s accounting

records against either agreement number.

Review of Reimbursable Agreements

The earnest money deposit from the CBSC has remained on NASA’s records for more than 15

years because the Office of the Chief Financial Officer did not review this reimbursable

agreement account on a regular basis. Section 9090 of the FMM requires that a final billing

statement be sent to reimbursable customers within 1 year of agreement completion. To

comply with the requirement, the Chief Financial Officer must review each agreement file

annually. There is no evidence of a review or follow-up by the Chief Financial Officer to

assess the status of the deposit account in the CBSC reimbursable agreement file.

Effect of Continued Deposit Retention

NASA’s continued retention of the CBSC’s earnest money deposit of $199,985 places the

Agency in the position of retaining funds to which it may not be entitled. The Office of Space

Flight informed us that there might be other deposits on NASA’s records for which

reimbursable services were never provided. NASA’s Office of General Counsel was unable

to cite a legal precedent permitting NASA to keep customer deposits for Agency use when

services had not been provided. Management should take actions to appropriately review and

disposition the CBSC deposit account and any other reimbursable international agreement

deposit accounts for which there has been no cost activity since receipt of earnest money

deposits.
8

Recommendations for Corrective Action

The NASA Chief Financial Officer should:

2. Promptly record any costs identifiable with the CBSC earnest money deposit, and

appropriately dispose of the balance in the appropriate deposit account.

3. Review other reimbursable international agreement accounts for which there has been no

cost activity since receipt of earnest money deposits to determine the appropriateness of

deposit retention.

Management’s Response

Concur. For recommendation two, management stated that the entire balance of $199,985

was transferred to the U.S. Treasury as miscellaneous receipts in December 1999. With

respect to recommendation three, management is reviewing all international agreement

accounts to determine the appropriateness of deposit retention. The anticipated completion

date for this review is March 2000.

Evaluation of Management’s Response

The actions taken and planned by management are responsive to the recommendations. We

consider the actions sufficient to disposition recommendation two, which will be closed for

reporting purposes. Recommendation three is considered resolved, but will remain

undispositioned and open until agreed-to corrective actions are implemented.
9

Appendix A. Objectives, Scope, and Methodology

Objectives

The overall objective of the audit was to determine whether NASA’s management of

international agreements is adequate. Our objective as discussed in this report was to

determine whether international agreements were appropriately executed and monitored.

The remaining audit objectives, which will be addressed in a separate audit report, were to

determine whether:

• appropriate clearances were obtained for foreign personnel with access to NASA facilities

and information, and

• controls over release of information were established.

Scope and Methodology

We obtained an overall understanding of how international agreements are managed and

administered at both NASA Headquarters and Center levels. We performed a limited review

of operating procedures at NASA Headquarters and at Goddard Space Flight Center

(Goddard). During the audit, we:

• Identified and reviewed NASA’s policies and procedures for management and

administration of international agreements.

• Interviewed personnel in NASA’s Office of External Relations, NASA’s Office of

Management Systems, Goddard’s International Visit Coordinator’s Office, Goddard’s

Security Office, and the Goddard International Projects Office to obtain an understanding

of operating procedures.

• Reviewed nonreimbursable and reimbursable agreements for compliance with NASA’s

approval process.

• Performed limited testing of agreements more than 9 years old to assess the adequacy of

management oversight.

To test the validity of data in the Office of External Relation’s international agreements

database, we judgmentally selected a sample of 812 agreements from a total universe of 3,202

agreements recorded in the database as of May 1999. The sample represented the

international agreements approved from January 1, 1990, through March 24, 1999. We

compared each selected record in the database to documentation maintained in the library to

assess the accuracy of the information in the database.
10

Appendix A

Management Controls Reviewed

We reviewed management controls at NASA Headquarters and Goddard. The significant

management controls related to NASA’s international agreements are contained in:

• NASA Policy Directive 1360.2, “Initiation and Development of International Cooperation

in Space and Aeronautic Programs,” April 19, 1999.

• NASA Procedures and Guidelines 1050.1, “Space Act Agreements Manual,”

December 30, 1998.

• NASA Policy Directive 1050.1F, “Authority to Enter into Space Act Agreements,”

November 13, 1998.

• NASA Policy Directive 1440.6E, “NASA Records Management,” April 29, 1997.

• NASA Financial Management Manual 9090, “Reimbursable and Other Customer

Agreements,” June 1999.

Management controls were generally considered adequate pertaining to the overall

management and administration of international agreements. The opportunity to further

strengthen these controls exists through implementation of the recommendations in this

report.

Audit Field Work

We conducted field work from April through October 1999 at NASA Headquarters and

Goddard. We performed the audit in accordance with generally accepted government auditing

standards.
11

Appendix B. NASA News Release
12

Appendix C. Management’s Response
13

Appendix C
14

Appendix C
15

Appendix C
16

Appendix D. Report Distribution

National Aeronautics and Space Administration (NASA) Headquarters

A/Administrator

AI/Associate Deputy Administrator

B/Chief Financial Officer

B/Comptroller

BF/Director, Financial Management Division

G/General Counsel

H/Associate Administrator for Procurement

I/Associate Administrator for External Relations

J/Associate Administrator for Management Systems

JM/Director, Management Assessment Division

L/Associate Administrator for Legislative Affairs

M/Associate Administrator for Space Flight

R/Associate Administrator for Aero-Space Technology

S/Associate Administrator for Space Science

U/Associate Administrator for Life and Microgravity Sciences and Applications

Y/Associate Administrator for Earth Science

NASA Centers

Director, Goddard Space Flight Center

Chief Counsel, John F. Kennedy Space Center

Non-NASA Federal Organizations and Individuals

Assistant to the President for Science and Technology Policy

Deputy Associate Director, Energy and Science Division, Office of Management and Budget

Branch Chief, Science and Space Programs Branch, Energy and Science Division, Office of

 Management and Budget

Associate Director, National Security and International Affairs Division, Defense Acquisition

 Issues, General Accounting Office

Professional Assistant, Senate Subcommittee on Science, Technology, and Space

Chairman and Ranking Minority Member - Congressional Committees and

Subcommittees

Senate Committee on Appropriations

Senate Subcommittee on VA, HUD, and Independent Agencies

Senate Committee on Commerce, Science, and Transportation

Senate Subcommittee on Science, Technology, and Space

Senate Committee on Foreign Relations

Senate Committee on Governmental Affairs
17

Appendix D

Chairman and Ranking Minority Member - Congressional Committees and

Subcommittees (Cont.)

House Committee on Appropriations

House Subcommittee on VA, HUD, and Independent Agencies

House Committee on Government Reform and Oversight

House Committee on International Relations

House Subcommittee on National Security, Veterans Affairs, and International Relations

House Committee on Science

House Subcommittee on Space and Aeronautics

Congressional Member

Honorable Pete Sessions, U.S. House of Representatives
NASA Assistant Inspector General for Auditing

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Major Contributors to this Report

Kevin J. Carson, Program Director, Safety and Technology Audits

William A. Garay, Auditor-in-Charge

Diane R. Choma, Auditor

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