U.S. Department of Energy 

Office of Inspector General 

Office of Audit Services 

Special Report 

The Department's Unclassified 

Foreign Visits and Assignments 

Program

DOE/IG-0791 March 2008 
Department of Energy 

Washington, DC 20585 

March 24, 2008 

MEMORANDUM FOR THB SECREIARY 

FROM: 

Inspector General 

SUBJECT: INFORMATION: Special Report on "The Department's 

Unclassified Foreign Visits and Assignments Progran~" 

BACKGROUND 

The Department of Energy's national laboratories and various Federal officials interact 

with thousands of foreign national visitors and assignees every year. Visits and 

assignments are for a variety of purposes, including research collaborations and acccss to 

scientific user facilities. While the Department reports that these interactions stimulate 

ideas and foster research, they also carry inherent security risks. The Office of Foreign 

Visits and Assignments and the Office of Intelligence and Counterintelligence help the 

Department ensure that security risks are addressed while fostering collaboration with 

foreign nationals. 

In our report on The Depurhnetlt's Utlclussijied Foreigt~ Visits utld Assignmerzts Progrum 

(DOEIIG-0579, December 2002), we observed that the Department had not adequately 

controlled unclassified visits and assignments by foreign nationals. That audit identified 

issues such as admitting visitors prior to receiving required approvals, not completing 

background checks, and neglecting to enter appropriate and accurate infornlation into the 

Department's Foreign Access Central Tracking Systcm (FACTS). Management agreed to 

take corrective action and has since issued a new Department order to govern these 

activities. Due to the sensitivity of the program and the potential for harm, we initiated 

this review to determine whethcr thc Department had improved the management of its 

Foreign Visits and Assignments Program. 

OBSERVATIONS AND CONCLUSIONS 

The Department had addressed several previously reported issues. Additional and 

continuing weaknesses, however, diminished the effectivcncss of controls designed to 

reduce the security risk associated with foreign visits and assignments. In particular, 

hosts for foreign nationals - individuals responsible for the day-to-day management and 

security associated with visits or assignments - had not ensured that a number of 

protective measures were implemented. For example, certain hosts did not always: 

Take action to ensure that site or facility access was terminated when the foreign 

nationals completed visits or assignments. In one extreme case, we found that a 

visitor, whose assignment had been revoked, did not have his access authorization 

cancelled and was able to cnter the former host facility after normal operating 

hours without being discovered; 
2

• Familiarize themselves with or enforce specific security plans – plans designed to 

restrict movements, activities and/or access – for visitors they were assigned to 

host from sensitive countries such as China and India; 

• Verify the identity and validity of foreign nationals' immigration status 

information prior to or periodically during assignments or visits as required for 

off-site visits; and, 

• Ensure that required counterintelligence reviews were conducted prior to 

permitting foreign nationals to access sensitive information systems and data. 

We also identified a significant and continuing problem with the maintenance and 

accuracy of FACTS that detracted from the Department's ability to track the immigration 

status or other factors for its many foreign visitors and assignees. Specifically: 

 

• For 104 of the 188 (approximately 55 percent) randomly selected FACTS visits or 

assignments we reviewed, tracking information was not properly entered, 

contained errors, or was not up-to-date. 

When viewed collectively, these problems or programmatic shortcomings caused us to 

conclude that security risks associated with the Department's Foreign Visits and 

Assignments Program remain higher than necessary. Contractor operated laboratories 

had not ensured that hosts were cognizant of their responsibilities and were performing 

them properly. Those laboratories and the Office of Foreign Visits and Assignments also 

had not taken sufficient steps to ensure that data in the FACTS was reliable. Problems 

with recordkeeping and tracking could limit the Department's ability to provide accurate 

and/or complete foreign national information to law enforcement agencies. 

To its credit, the Department had addressed a previously identified issue – ensuring that 

foreign nationals had current passports and visas for on-site visits and assignments. Yet, 

we concluded that more needs to be done to reduce the risk that individuals harboring 

malicious intent could access sensitive information or damage facilities. Thus, the 

attached report includes several recommendations designed to address the problems noted 

in our review. 

We also noted another matter for consideration pertaining to cyber access controls at one 

National Nuclear Security Administration (NNSA) laboratory. This matter is discussed 

more fully in Appendix 2 of the report. 

MANAGEMENT COMMENTS

Management generally concurred with our findings and recommendations and in certain 

instances indicated that corrective actions had been initiated. NNSA submitted informal 

comments and indicated that it would develop corrective actions and monitor progress to 

completion. Formal Management comments are included as Appendix 4. 

Attachment 

cc: Acting Deputy Secretary

Administrator, National Nuclear Security Administration 
Under Secretary of Energy 

Under Secretary for Science 

Chief of Staff 
SPECIAL REPORT ON THE DEPARTMENT'S UNCLASSIFIED 

FOREIGN VISITS AND ASSIGNMENTS PROGRAM 

TABLE OF 

CONTENTS 

Management of Unclassified Foreign Visits and Assignments

Details of Finding ....................................................................................................1 

Recommendations....................................................................................................7 

Comments ................................................................................................................8 

Appendices 

1. Objective, Scope, and Methodology..................................................................9 

2. Other Matter for Consideration........................................................................11 

3. Prior Reports ....................................................................................................12 

4. Management Comments ..................................................................................13 
MANAGEMENT OF UNCLASSIFIED FOREIGN VISITS AND 

ASSIGNMENTS 

________________________________________________________________ 

Page 1 Details of Finding

Tracking and Hosting Weaknesses in hosting and tracking diminished the 

Foreign Nationals effectiveness of the Department of Energy's (Department) 

Foreign Visits and Assignments Program. In particular, our 

review of foreign visits at four laboratories and two 

Headquarters offices revealed that foreign national hosts 

were not performing a number of required tasks. 

Specifically hosts did not always: (1) take action to ensure 

that site or facility access was properly and promptly 

terminated when the visit or assignment was completed; 

(2) become familiar with and ensure that visitors or 

assignees complied with individualized security plans; (3) 

verify the identity and validity of foreign nationals' status 

information for off-site visits as required; and, (4) ensure 

that counterintelligence reviews were completed prior to 

permitting foreign nationals to access sensitive information 

systems and data. We also noted that a significant and 

continuing problem with the maintenance and accuracy of 

the Department's Foreign Access Central Tracking System 

(FACTS) had not been resolved. 

Host Responsibilities and Actions

To help reduce risk, the Department requires that a host be 

appointed to define and control the work and access of each 

visitor or assignee. Hosts are responsible for the successful 

conduct of the foreign visit, including keeping site officials 

informed of the visit or assignment status; ensuring 

tracking systems are kept up-to-date with accurate and 

complete information; and complying with visitor-specific 

security plans. In addition, in certain cases such as at offsite meetings, the host must obtain and/or validate foreign 

national status documentation, i.e. visas and passports. 

These required actions are particularly important because 

nearly all of our sampled visitors represented countries 

such as the People's Republic of China, India, and Russia – 

states that are considered "sensitive" because of national 

security, nuclear nonproliferation, or terrorism support 

concerns. As detailed in the following paragraphs, 

however, we discovered that hosts were often not always 

aware of the full scope of their duties or mistakenly 

believed that other organizations or individuals were 

responsible for satisfying security requirements. 
 

________________________________________________________________ 

Page 2 Details of Finding

Updating Visit or Assignment Status 

Hosts at various sites told us that they had not always kept 

site officials informed of the status of visits or assignments 

as required. Many of the hosts stated that even though they 

were aware that a particular collaboration had ended or a 

need to visit a user facility no longer existed, they had not 

notified Foreign Visits and Assignments Program managers 

that the visit should be closed out and facility access 

terminated. We found, based on host interviews at one 

laboratory, that 14 of the 27 foreign nationals selected for 

review no longer needed site access because the visit or 

collaboration had been completed. For example, one 

assignee no longer needed access to the user facility at a 

particular laboratory because he was conducting his 

research at another laboratory. In another case, an 

assignee, that accepted a job in Italy, had reportedly 

departed the United States and was no longer involved in a 

project with the laboratory. Another host told us that a 

particular assignee had completed the work and the 

collaboration was no longer necessary. 

Security Plans 

Hosts were not always cognizant of and did not enforce 

security plans designed to restrict the access and/or scope 

of the visitor or assignee. For visitors and assignees from 

sensitive countries, a specific security plan must be 

developed for each foreign national. These security plans 

are required to address concerns such as the type of security 

area to be visited and types of information to be accessed. 

Four of the nine hosts interviewed at one Office of Science 

(Science) laboratory advised us that they did not have a 

specific security plan in their possession nor were they 

otherwise familiar with the content of the security plan. At 

another Science laboratory, 12 of 23 hosts indicated that 

they were unfamiliar with the specific security plans for 

their visitors. At both locations, many hosts said that 

individual security plans were maintained by an 

administrative staff member in their division, but the 

security plans were neither provided to nor read by the 

host. 

Validating Status Documentation 

At one National Nuclear Security Administration (NNSA) 

laboratory and one Headquarters office, hosts were not 
 

________________________________________________________________ 

Page 3 Details of Finding

always obtaining and/or validating status documents such 

as passports and visas for foreign visitors as required. 

Hosts for visitors at the NNSA laboratory were specifically 

required to take these actions for visitors or assignees not 

physically working at the laboratory; i.e., those involved in 

collaborations at off-site locations. In some cases, hosts 

arranged for this class of visitor or assignee to obtain 

remote access to the laboratory's information systems. 

Hosts are responsible for obtaining and providing up-todate status documents to the foreign visits office in these 

instances and also examining previously-provided 

information to validate the identity of foreign nationals. 

At the NNSA site where foreign visitors were involved in 

off-site collaborations, hosts were not always obtaining 

immigration status information from foreign visitors. In 

three of four cases we reviewed involving off-site 

collaboration, the hosts indicated that they did not obtain 

up-to-date status information for visitors, nor did they 

provide the information to the foreign visits office. These 

hosts also did not visually inspect status documents. As a 

result, status information for these visitors did not exist or 

was not accurate in either the site foreign visitor tracking 

database or FACTS and it was uncertain that the foreign 

nationals were in valid status for the duration of the visit or 

assignment. 

During our testing at one Headquarters office, we also 

learned that despite Departmental security requirements to 

the contrary, hosts were not required by that office to 

visually inspect and verify passport and visa information at 

the time of foreign visitor arrival at Headquarters facilities. 

Obtaining and validating up-to-date status documents 

ensures that passport and visa information is correct before 

allowing access to Department facilities and is important to 

demonstrate that an individual's identity and authority to 

work are valid, access for certain activities is appropriate, 

and the foreign national is eligible to be in the United 

States. During the course of our review, the Headquarters 

office in question acknowledged this weakness and 

immediately mandated the verification of passport and visa 

data. 

Access to Sensitive Data 

At one NNSA laboratory, some hosts were not providing 

necessary information to ensure that required 
 

________________________________________________________________ 

Page 4 Details of Finding

counterintelligence reviews were conducted prior to 

permitting foreign nationals to access sensitive information 

systems and data. Department directives mandate that a 

counterintelligence review must occur for all foreign 

nationals who have access or potential access to sensitive 

information. Such information may reside on computer 

systems and could include categories of unclassified 

controlled information such as export control, proprietary, 

or unclassified controlled nuclear information. Hosts did 

not always ensure an annotation was made in the 

"sensitive" subject field of the laboratory's foreign national 

tracking system – an action that would automatically 

trigger the performance of needed national indices checks 

and local counterintelligence reviews. 

Centralized Tracking

Similar to the issue identified in The Department's 

Unclassified Foreign Visits and Assignments Program

(DOE/IG-0579, December 2002), laboratories were still not 

ensuring that the Department's official complex-wide 

database for tracking all foreign national visitors and 

assignees was current and complete. Biographical and 

personal information, including passport and visa 

information, for each foreign visitor, is required to be 

entered by field sites into FACTS, the Department's official 

database. Such information contains identification 

numbers and passport and visa expiration dates and is 

critical because visitors are not authorized to be in the 

United States without current credentials. While field sites 

are allowed to maintain their own tracking systems, 

FACTS is the only foreign visitor tracking database 

authorized by the Department and is the official source 

used to report information to Congress and other 

stakeholders. Because sites are maintaining their own 

systems, the Department permits sites to upload data to the 

FACTS from site-level tracking systems to eliminate the 

burden of duplicate entry. Our analysis, however, 

established that three of the four national laboratories in our 

review were not ensuring that site-level information was 

correct in FACTS. 

Testing of FACTS data for one NNSA and two Science 

laboratories revealed significant and continuing problems 

with the accuracy of legal status documentation, such as 

visa and legal permanent resident information. For 104 of 

the 188 randomly selected visitors we reviewed, all of 
 

________________________________________________________________ 

Page 5 Details of Finding

which were from sensitive countries, tracking information 

was not properly entered, contained errors, or was not upto-date. Specifically, 53 of the 58 sampled visitors at an 

NNSA laboratory, 32 of 64 sampled visitors at one Science 

laboratory, and 19 of 66 sampled visitors at another Science 

laboratory either contained no legal status information or 

such data was out-of-date. 

Additionally, the three laboratories were not ensuring that 

visits were closed in FACTS within the prescribed 15 day 

timeframe. Of the 179 completed visits we evaluated, 96 

had not been closed within the prescribed time period. The 

table below illustrates the number of days taken to 

officially close each visit associated with our sampled 

foreign national visitors. 

Number of Days to Close Visit or 

Assignment

15 or 

Fewer 

16-

90 

Over 

90 

Total 

Science 

Laboratory

23 19 11 53 

Science 

Laboratory

19 17 0 36 

NNSA 

Laboratory

41 12 37 90 

Totals 83 48 48 179 

It is important to note that 24 visits or assignments 

remained open for more than a year after they should have 

been closed. 

In a related issue, at both of the Science laboratories, 

visitors and assignees were often given access to the sites 

for a two-year time period although they may or may not be 

at the site for that entire duration. This practice was used 

primarily to accommodate visits to user facilities for which 

actual visit dates were unknown at the initiation of the visit 

or assignment. In many cases, the purpose for the initial 

visit may be accomplished in less time, but the visit is not 

"closed" until the end of the two-year period. As a 

consequence, visitors or assignees unnecessarily retain their 

security badges and have the ability to access the site for 

the entire two-year period.
 

________________________________________________________________ 

Page 6 Details of Finding

Departmental Foreign Hosting and tracking weaknesses existed because: 

National Tracking (1) site foreign visits and assignments managers were not 

and Hosting validating that hosts were meeting established 

Requirements requirements; and, (2) neither field sites nor Headquarters 

 officials were conducting basic data comparisons. 

Validating Host Activities

Although host-specific training existed, laboratories in our 

review were not validating that hosts were effectively 

fulfilling their responsibilities. Each of the laboratories 

required specific training to qualify individuals to host 

foreign nationals. Training generally covered requirements 

regarding notification of visit or assignment end dates, 

familiarity with specific security plans, and information 

hosts should be providing, such as a need for access to 

sensitive information. While all hosts we interviewed had 

received the applicable training, they were not meeting 

many of their hosting requirements and responsibilities. 

Data Comparisons

Organizations also did not take action to ensure that foreign 

visit information was correct and/or periodically 

reconciled. Based on the extensive differences identified in 

our comparison of site-level foreign visit information to 

data in FACTS, we concluded that field sites were not 

conducting basic comparisons of data maintained in their 

own tracking systems to that in FACTS. Our work 

demonstrated that even basic visual data checks – such as 

comparing the expiration dates of visas between the 

systems – would have revealed inadequacies with data in 

FACTS. Further, while FACTS had the capability to sort 

and search data, the Office of Health, Safety and Security's 

(HSS) Office of Foreign Visits and Assignments had not 

built basic edit checks into FACTS and was not otherwise 

using program tools to identify problems such as visa 

expiration dates that preceded end visit dates or visits that 

did not have visa information at all. For example, a review 

of FACTS data from one Office of Science site revealed 

that visas for 15 of 66 visitors in our sample had expired 

before their visits even began. 

Mitigating Security Weaknesses in the Department's foreign visits and 

Risks assignments program increase the security risk for the 

Department's facilities and information. For example, at 

least one visitor accessed a laboratory using a valid 

identification badge on two occasions the month after his 
 

________________________________________________________________ 

Page 7 Recommendations

assignment had been revoked. Site officials were unaware 

of the unauthorized access until we brought it to their 

attention. 

The unauthorized access is exacerbated by the fact that the 

same visitor's background check had expired four months 

prior to the two unauthorized visits, which were made after 

the site's normal operating hours. Due to the fact that 

foreign national maintained an active visit and security 

badge in laboratory systems, he was able to access the site 

without question. Neither the host nor other site officials 

could explain his purpose or whereabouts on the site. The 

situation could have been avoided had the visit been closed 

and site access terminated at the same time the assignment 

was revoked. 

While the Department must adhere to its mission to foster 

and advance scientific research and development, 

minimizing risks is important because the national 

laboratories hold some of our most valuable national 

security assets. Research essential to our national defense 

relies increasingly on unclassified science and technology, 

and thousands of foreign nationals from institutions around 

the world interact with laboratory employees at Department 

facilities. While we recognize that documenting and 

tracking foreign national visitors and assignees requires 

additional attention and effort at the site-level, the risk or 

damage to the Nation's security interests demand vigilance. 

The Department must ensure that it maintains needed 

information and is prepared to respond to inquires in a 

timely manner. 

RECOMMENDATIONS To help ensure that Department requirements for foreign 

national accountability, access and control are 

comprehensively detailed and consistently applied, we 

recommend that the Administrator, NNSA and the Under 

Secretary for Science require that field sites: 

1. Ensure hosts are meeting requirements for 

updating visit status, familiarizing themselves 

with specific security plans, validating status 

documentation as necessary, and providing full 

details of required sensitive information access;
 

________________________________________________________________ 

Page 8 Comments

2. Take immediate action to close completed visits 

or assignment in FACTS and terminate access to 

sites and facilities that is no longer required; and 

3. Ensure required foreign visitor and assignee 

information is accurate and complete in FACTS. 

To help ameliorate increased risks associated with foreign 

national interaction and ensure that complete status 

information is available, we recommend that the Chief 

Health, Safety and Security Officer: 

4. Require that the Office of Foreign Visits and 

Assignments implement data comparisons, 

including edit checks and/or error reports 

generated on a periodic basis, to help ensure that 

information entered into FACTS is accurate and 

complete. 

MANAGEMENT Management agreed with the information in the report 

REACTION and generally concurred with each of the specific 

recommendations. In a joint response, the Offices of 

Science and HSS provided comments on intended actions. 

Science is taking immediate action to work with its 

Integrated Support Center to close visits and assignments 

that are no longer required. Additionally, Science will 

work closely with field sites and HSS in implementing the 

additional recommendations. HSS responded that its 

Office of Foreign Visits and Assignments had already 

begun development of a FACTS modification to add edit 

checks and error reports to reject the entry of inaccurate 

and/or incomplete information. In its informal comments, 

NNSA indicated that it concurred with the findings and 

recommendations and pledged to take necessary corrective 

actions. It did not, however, provide a corrective action 

plan. 

AUDITOR Management's comments are responsive to our 

COMMENTS recommendations. 
Appendix 1 

________________________________________________________________ 

Page 9 Objective, Scope, and Methodology 

OBJECTIVE The objective of our review was to determine whether the 

Department of Energy (Department) had improved the 

management of its Foreign Visits and Assignments Program. 

SCOPE The review was performed at Headquarters and four national 

laboratories, two managed by the Office of Science (Science) 

and two managed by the National Nuclear Security 

Administration (NNSA), from August 2006 through February 

2008. The universe of our samples consisted of foreign 

national visitors, assignees, and employees at those sites from 

October 2004 through May 2007. 

METHODOLOGY To accomplish our objective, we: 

• Reviewed Department and site-specific policies, 

procedures, and training materials related to 

unclassified foreign national visits and assignments; 

• Reviewed lists of foreign national visitors, assignees, 

and employees provided by the Department's Foreign 

Access Central Tracking System, site badge systems, 

and site foreign visits and assignment systems; 

• Randomly selected samples of 66 sensitive country 

foreign national visitors, assignees, and employees from 

one Science-managed laboratory, 64 from the other 

Science-managed laboratory, and 58 from the NNSAmanaged laboratory; 

• Judgmentally selected a sample of 100 sensitive and 

non-sensitive country foreign national visitors and 

assignees from the other NNSA-managed laboratory; 

• Randomly selected samples of 55 and 54 visitors and 

assignees from each of the Headquarters offices 

selected for review; 

• Reviewed supporting documentation for our sample of 

foreign national visitors, assignees, and employees; 

• Interviewed officials from the Headquarters Office of 

Foreign Visits and Assignments, Counterintelligence, 

and selected site security, foreign visits, and 

Counterintelligence offices to gain and understanding 

of roles, responsibilities, and procedures; and,
Appendix 1 (continued) 

________________________________________________________________ 

Page 10 Objective, Scope, and Methodology 

• Interviewed officially-designated foreign national hosts 

judgmentally selected from our samples to obtain 

supporting information on visitors or assignees. 

We assessed performance measures established under the 

Government Performance and Results Act of 1993. While 

specific performance measures concerning foreign visits and 

assignments did not exist, performance in this regard was 

either measured by each laboratory's safeguards and securities 

reviews or will be enhanced with the implementation of our 

recommendations and suggestions. 

Management waived an exit conference. 
Appendix 2 

______________________________________________________________

Page 11 Other Matters for Consideration 

OTHER MATTERS FOR CONSIDERATION

In addition to weaknesses identified in the overall unclassified Foreign Visits and 

Assignments Program discussed in this report, we also identified an additional cyberspecific issue at one of the National Nuclear Security Administration (NNSA) 

laboratories in our review. Specifically, the laboratory had not fully mitigated the risk of 

foreign nationals gaining unauthorized access to its unclassified Intranet. 

Officials at one NNSA laboratory indicated that security features on many laboratory 

desktop and laptop computers used by foreign national visitors and assignees were not 

always implemented. We learned from laboratory security officials that software controls 

designed to prevent foreign nationals from circumventing security features were 

implemented on laboratory computers assigned to sensitive country foreign nationals. 

These controls were not, however, implemented on most computers assigned to nonsensitive country foreign nationals. According to officials, users circumventing security 

features on computers could modify log-on settings, load unauthorized software, remove 

software, and change computer settings – ultimately permitting unauthorized access to 

the laboratory's information systems. 

Laboratory officials also revealed that some foreign visitors and assignees enjoyed 

unsupervised use of their foreign government, university, or business laptops in 

laboratory facilities with live Intranet connections. Both Department and laboratory 

policy allows both U.S. citizens and non-sensitive country foreign nationals to bring their 

government, business, or university laptop computers on to the site for unclassified, 

stand-alone use. Counterintelligence officials at the laboratory told us that they were 

concerned with the current practice because foreign nationals could connect their 

computer equipment to the laboratory's Intranet without authorization. These 

connections pose a threat and could permit the foreign nationals to download large 

amounts of data, probe the network for vulnerabilities, and implant malicious code. 

SUGGESTIONS FOR IMPROVEMENT 

To help decrease the risk associated with foreign national data access and computer 

operation, we suggest that NNSA require the laboratory to: 

1. Strengthen security and access controls for computers operated by foreign 

nationals to help prevent or detect unauthorized or malicious use; and, 

2. Specifically restrict the connection of all non-U.S. Government owned equipment 

to the laboratory's network and Intranet. 
Appendix 3 

________________________________________________________________ 

Page 12 Prior Reports 

PRIOR REPORTS

Office of Inspector General

• The Department's Unclassified Foreign Visits and Assignments Program

(DOE/IG-0579, December 2002). That audit identified three deficiencies in 

adequately controlling unclassified visits and assignments at two national 

laboratories. Those deficiencies included failures to ensure that: (1) all foreign 

nationals had current passports and visas; (2) foreign nationals were not granted 

site access prior to official approval and before background checks or 

counterintelligence consultations were completed; and, (3) sufficient information 

was provided to the Department of Energy's (Department) centralized tracking 

system, which was designed to facilitate complex-wide tracking of the status of 

foreign nationals. 

• Our office conducted a series of annual Inspections from 2000 – 2006 of export 

licensing controls in the Department. These inspections were also part of an 

effort with other agencies that conduct these activities such as Commerce, 

Defense, and Homeland Security. The most recent inspection, The Department of 

Energy's Review of Export License Applications for China (DOE/IG-0723, April 

2006), concluded that the export license review process to control the export of 

critical technologies to China was appropriate and consistent with existing 

procedures. However, it also noted that access by Department officials 

conducting license reviews to end user-review information maintained by one 

National Nuclear Security Administration laboratory could be improved, and 

included a recommendation to address the concern. Additionally, it reported that 

12 of 15 recommendations made in the earlier Inspections had been closed, but 

that export control guidance still needed to be consistently implemented 

throughout the Department complex and appropriate action was necessary to 

ensure that licensing officers have access to and proper training in the use of the 

Department of Commerce's Export Control Automated Support System. 
Appendix 4 

________________________________________________________________ 

Page 13 Management Comments 
Appendix 4 (continued) 

________________________________________________________________ 

Page 14 Management Comments 
IG Report No. DOE/IG-0791

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