DEFENSE 

LOGISTICS

Greater Awareness of 

Recommendations 

and Improvements in 

Data Quality Needed 

to Resolve ContainerManagement 

Challenges

Report to the Committee on Armed 

Services, House of Representatives

November 2014

GAO-15-114

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-15-114, a report to the 

Committee on Armed Services, House of 

Representatives

November 2014

DEFENSE LOGISTICS

Greater Awareness of Recommendations and 

Improvements in Data Quality Needed to Resolve 

Container-Management Challenges

Why GAO Did This Study

DOD uses DOD or commercial carrier 

shipping containers to transport 

supplies worldwide. Container 

management has been a long-standing 

challenge. DOD has paid detention 

fees of about $823 million from 2003 

through 2012 for retaining containers 

longer than allowed, primarily due to 

operations within CENTCOM, including 

Afghanistan, where fees continue to 

accrue. GAO was asked to review 

DOD’s efforts to address containermanagement challenges and the 

accumulation of detention fees. 

This report assesses the extent to 

which (1) DOD policy and guidance 

incorporate recommendations 

addressing container-management 

challenges in CENTCOM’s area of 

responsibility, and (2) DOD has 

managed and reduced detention fees 

for containers in Afghanistan since 

2012. GAO reviewed prior audit reports 

to identify container-management 

recommendations; analyzed data such 

as container type and ownership from 

2010 through 2013; and interviewed 

DOD officials.

What GAO Recommends

GAO recommends that DOD (1) 

develop a list of recommendations and 

incorporate them into policy and 

guidance and (2) identify root causes 

for procedural weaknesses that 

contribute to inaccurate, incomplete 

container data and develop and 

implement a corrective plan. DOD 

concurred with the first 

recommendation and partially 

concurred with the second because it 

partially disagreed to whom GAO 

directed the recommendation. GAO 

concurred and modified the 

recommendation.

What GAO Found

Since the early years of operations in Afghanistan and Iraq, Department of 

Defense (DOD) efforts to improve container management in the U.S. Central 

Command (CENTCOM) area of responsibility have included either updating 

existing or developing new container-management policy and guidance. 

However, the department cannot provide reasonable assurance that all 

recommendations addressing container management in the CENTCOM area of 

responsibility have been incorporated in DOD’s policy or guidance, as 

appropriate. DOD officials incorporated some recommendations made by DOD 

audit agencies and other organizations aimed at improving container 

management into policy and guidance. For example, in August 2012 the 

commanders of CENTCOM and U.S. Transportation Command issued a joint 

memorandum outlining leadership’s responsibility for container management in 

the CENTCOM area of responsibility that was a direct result of a 2012 Joint 

Logistics Board report that recommended corrective actions to enhance senior 

leaders’ understanding of container management. However, DOD does not have 

a comprehensive list of the corrective actions that have been recommended over 

time. Without such a list, DOD cannot reasonably ensure that all of the 

recommendations have been incorporated into policy and guidance as 

appropriate. For example, of the 95 corrective actions that GAO identified from 

reports by DOD audit agencies and other organizations issued from 2003 

through 2013, DOD officials could not provide information on steps taken to 

address 40 of the corrective actions.

Since 2012, DOD has taken steps to manage and reduce shipping container 

detention fees incurred due to the untimely return of commercial carrier-owned 

shipping containers in Afghanistan, but its ability to manage and reduce these 

fees is limited by inaccurate and incomplete data. In August 2012, DOD 

established the requirement that within 15 days of a shipping container’s arrival: 

(1) receipt of the container was to be recorded by the unit in-theater, (2) the 

container was to be unloaded, and (3) the responsible carrier was to be notified 

that its container was available for pickup. DOD also developed a set of tracking 

metrics to monitor progress in meeting this requirement. However, incomplete 

and inaccurate data about the location and number of containers accruing 

detention fees hindered DOD’s ability to manage and reduce detention fees for 

containers in Afghanistan. For example, GAO analysis of DOD’s containermanagement system data and carrier delivery data for each month in 2013 

showed that DOD had not recorded in the container-management system about 

16 percent of the carrier-owned containers delivered and received in 

Afghanistan. DOD has identified factors, or procedural weaknesses, that may 

contribute to incomplete and inaccurate data; however, it has not assessed the 

extent to which these weaknesses have contributed to data inaccuracies, 

determined the root causes of these weaknesses, or developed a correctiveaction plan for correcting them. Without an assessment of the root causes and a 

corrective-action plan, it will be difficult for DOD to have complete and accurate 

data, which could limit its ability to manage and reduce detention fees for 

View GAO-15-114. For more information, containers in Afghanistan and in future contingency operations.

contact Cary B Russell at 202-512-5431 or

russellc@gao.gov.
Page i GAO-15-114 Defense Logistics

Letter 1

Background 6

DOD Cannot Determine the Extent to Which Its Policy and 

Guidance Incorporate Recommendations to Improve Container 

Management in the CENTCOM Area of Responsibility 9

DOD Has Taken Steps to Manage and Reduce ShippingContainer Detention Fees in Afghanistan, but Its Ability to 

Manage and Reduce These Fees Is Limited 14

Conclusions 23

Recommendations for Executive Action 24

Agency Comments and Our Evaluation 24

Appendix I Scope and Methodology 27

Appendix II Comments from the Department of Defense 31

Appendix III GAO Contact and Staff Acknowledgments 34

Table

Table 1: Number of Reports Issued from 2003 through 2013 That

Included Recommendations to Improve ShippingContainer Management 13

Figures

Figure 1: Detention-Fee Payments for Containers Shipped to 

Afghanistan and Iraq in Fiscal Years 2003 through 2012 9

Figure 2: Comparison of DOD Containers in Afghanistan with 

Known and Unknown Locations on October 31, 2013 18

Contents
Page ii GAO-15-114 Defense Logistics

Abbreviations

DOD Department of Defense

CENTCOM U.S. Central Command

ISO International Organization for Standardization

This is a work of the U.S. government and is not subject to copyright protection in the 

United States. The published product may be reproduced and distributed in its entirety 

without further permission from GAO. However, because this work may contain 

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Page 1 GAO-15-114 Defense Logistics

441 G St. N.W.

Washington, DC 20548

November 21, 2014

The Honorable Howard P. “Buck” McKeon

Chairman

The Honorable Adam Smith

Ranking Member

Committee on Armed Services

House of Representatives

Afghanistan’s logistics environment is challenging for U.S. forces because 

Afghanistan is a mountainous, arid, land-locked country with poorly 

developed infrastructure, including few roads, no railway, and few airports 

with limited amounts of paved runways. Further, the Department of 

Defense’s (DOD) distribution of supplies and equipment into and within 

Afghanistan—a major operational area in the U.S. Central Command 

(CENTCOM) area of responsibility—is a complex process that involves 

many organizations and utilizes both surface and air modes of 

transportation over various routes. A major component of this distribution 

process involves the use of shipping containers to transport goods to, 

within, and from Afghanistan. For example, according to DOD containermanagement data, DOD managed, at its peak (January 2013), 

approximately 107,000 containers in Afghanistan, which included a 

combination of containers owned or leased by the U.S. government or 

provided by commercial shipping companies as part of DOD’s shipping 

contract with these carriers.

Container management for shipping containers, whether DOD-owned, 

leased, or carrier-owned, involves the tracking, storage, shipment, use, 

delivery, discharge, and return of the container to the common-user 

container fleet or to the owning carrier.1

 1

Common-use containers are leased, procured, or made available from governmentowned inventories to support the intermodal transportation requirements of all military 

services. These containers are managed and controlled by the U.S. Transportation 

Command through the Surface Deployment and Distribution Command while they support 

DOD transportation needs in peace and war. 

The management of these 

containers has been a long-standing challenge for DOD. According to 

DOD data, as of September 2014 the department has paid detention fees 

of $823 million from fiscal years 2003 through 2012 for retaining carrierowned containers used in Iraq and that are continuing to be used in 
Page 2 GAO-15-114 Defense Logistics

Afghanistan for longer periods of time than allotted contractually.2

We first reported on the issue of container management in 1977 and, 

along with other audit agencies, have issued reports since then identifying 

challenges related to container management. For example, in October 

2011, we found that reporting and tracking of containers in containermanagement systems was inconsistent for reasons including that the two 

container-management systems in use were not integrated, thus 

potentially creating gaps in information.

DOD 

currently estimates that detention payments for fiscal years 2013 and 

2014 will be approximately $41 million and $40 million, respectively.

3 We recommended that, to better 

manage its shipping-container processes, DOD should select a single 

container-management system for all DOD entities and contract carriers 

to track the containers’ status. DOD concurred with this recommendation 

and, in 2012, approved requirements for a single container-management 

system. DOD expects completion of an initial version of the system after 

the end of fiscal year 2014. Furthermore, since 1990, GAO has 

maintained a program to focus attention on government operations that it 

identifies as high risk due to their greater vulnerabilities to fraud, waste, 

abuse, and mismanagement or the need for transformation to address 

economy, efficiency, or effectiveness challenges. DOD’s supply-chain 

management, which includes container management, has been on GAO’s 

high-risk list since 1990.4

 2

Detention-fee data for fiscal years 2013 and 2014 were not fully known prior to issuance 

of this report because detention fees can accrue over a period of 350 to 700 days. 

Furthermore, payment of these fees for containers used in a given fiscal year may extend 

into subsequent fiscal years because billing for detention fees may not be done 

immediately following return of containers or notification to the carrier about the status of 

its containers. Moreover, until a contract is closed out, the contractor may continue to 

make detention-fee claims. Unless otherwise stated in this report, all dollar figures are in 

nominal terms, unadjusted for inflation.

In our most recent update to the high-risk list, 

we reported that DOD had taken steps to mitigate some of the challenges 

concerning supplying the warfighter in Afghanistan, but problems 

3

GAO, Warfighter Support: DOD Has Made Progress, but Supply and Distribution 

Challenges Remain in Afghanistan, GAO-12-138 (Washington, D.C.: Oct. 7, 2011). The 

two container-management systems in use that were not integrated were the U.S. 

Transportation Command’s system used to track and manage government-owned and 

carrier-owned shipping containers in use, including those in Afghanistan, and the U.S. 

Army’s system used to track container location and status of government-owned 

containers. 

4

GAO, High-Risk Series: An Update, GAO-13-283 (Washington, D.C.: February 2013).
Page 3 GAO-15-114 Defense Logistics

remained, including in effectively tracking and managing cargo 

containers.5

Aspects of DOD container-management responsibilities reside with a 

number of offices within the department. For example, the Office of the 

Deputy Assistant Secretary of Defense for Transportation Policy is 

responsible for establishing container-management policy. The Surface 

Deployment and Distribution Command, the logistics directorates for each 

of the military services, the Defense Logistics Agency, U.S. 

Transportation Command, and CENTCOM all have responsibilities for 

different facets of managing containers, including the purchasing, 

shipping, managing, and returning of containers while they are being 

used in theater.6

Given the continued challenges DOD faces as it works to improve 

container management and reduce detention fees, you asked us to 

review DOD’s efforts to improve container management in the CENTCOM 

area of responsibility in light of container detention fees. This report 

examines the extent to which (1) DOD policy and guidance incorporate 

recommendations by DOD audit agencies and other organizations that 

address container-management challenges in the CENTCOM area of 

responsibility, and (2) DOD has managed and reduced detention fees for 

containers in Afghanistan.

To address the first objective, we reviewed DOD policy and guidance 

pertaining to container management to develop our understanding of 

container-management operations and roles and responsibilities. We then 

reviewed reports issued from calendar years 2003 through 2013 by all 

audit agencies we identified as having done work on the subject of 

container management at DOD: the Army Audit Agency, the Naval Audit 

Service, the Air Force Audit Agency, the DOD Office of Inspector 

General, the Defense Contract Audit Agency, the Defense Contract 

Management Agency, the Special Inspector General for Iraq 

Reconstruction, the Special Inspector General for Afghanistan 

 5

GAO-13-283.

6

See Deputy Secretary of Defense Memorandum, Global Container Management Policy

(Dec. 18, 2009).
Page 4 GAO-15-114 Defense Logistics

Reconstruction, and GAO.7 We contacted and interviewed DOD logistics 

and container-management officials from the Office of the Deputy 

Assistant Secretary of Defense for Transportation Policy, U.S. 

Transportation Command, CENTCOM, the U.S. Army, the U.S. Marine 

Corps, the Surface Deployment and Distribution Command, and the 

Defense Logistics Agency to discuss efforts to improve container 

management and identify any additional reports and studies with findings 

and recommendations involving container-management issues potentially 

affecting DOD operations in CENTCOM’s area of responsibility.8 We also 

interviewed DOD officials to determine whether the department had 

undertaken efforts to identify recommendations addressing container 

management. We then analyzed the relevant recommendations 

contained in these reports and studies that we identified, noting the DOD 

components responsible for implementing them, and then categorized the 

recommendations based on common themes that emerged from our 

review of the reports. As a result, we were able to identify whether certain 

recommendations were repeated over the reporting period. We then 

reviewed DOD policy and guidance pertaining to container management 

to determine the extent that the recommendations we identified were 

reflected in them. We compared DOD’s inclusion of recommendations 

addressing container-management challenges into its policy and 

guidance documents according to criteria outlined in Standards for 

Internal Control in the Federal Government.

9

To address the second objective, we met with officials from the Office of 

the Deputy Assistant Secretary of Defense for Transportation Policy, U.S. 

Transportation Command, CENTCOM, the U.S. Army, the U.S. Marine 

Corps, the Surface Deployment and Distribution Command, and the 

Defense Logistics Agency to develop an understanding of how DOD 

accrues and pays detention fees and manages shipping containers to 

reduce the accumulation of detention fees. We also discussed and 

 7

We selected this period to correspond with the period DOD began tracking detention fees 

for operations in Iraq and Afghanistan through the completion of work on this objective of 

our review. We identified the noted agencies as those agencies providing 

recommendations based on our research. However, DOD did not have the means to verify 

or corroborate that our list was all-inclusive. 

8

For purposes of this report, the term “recommendation” includes written corrective 

actions and formal recommendations made by DOD components and other organizations. 

9

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

(Washington, D.C.: November 1999).
Page 5 GAO-15-114 Defense Logistics

observed the processes and procedures by which invoices for detention 

fees are received, reviewed, and paid, and observed demonstrations of 

the U.S. Transportation Command’s system used to track and manage 

government-owned and carrier-owned shipping containers used in the 

CENTCOM area of responsibility including in Afghanistan. In addition, we 

collected comprehensive listings from 2013 of the containers and any 

associated data, including, for example, the date a container arrived in

theater, the container type, and the ownership of the container; and 

analyzed the data to understand the amounts and uses of shipping 

containers in Afghanistan. We also collected all available end-of-month 

DOD listings—from September 2010 through December 2013—of carrierowned shipping containers subject to detention fees to conduct our own 

analysis. We selected September 2010 because it was the first month for 

which DOD had available end-of-month data. We concluded with 

December 2013 because it was the cutoff date for the analyses that we 

had planned to conduct. We compared our observations, data we 

collected, and our analyses with Standards for Internal Controls in the 

Federal Government and DOD guidance such as the Defense 

Transportation Regulation and CENTCOM’s Container Management 

Policy Letter of Instruction that specify the need to accurately and timely 

record data that has an effect on detention fee accrual.10 We also 

assessed DOD’s efforts to improve its management of container data 

against best practices for improving federal agency performance and 

accountability and against Standards for Internal Control in the Federal 

Government, which address risks and accountability for achieving 

effective results.11

 10

In addition, we assessed the reliability of the container 

data by reviewing related documentation, interviewing knowledgeable 

officials, and testing the data for obvious errors and completeness. We 

GAO/AIMD-00-21.3.1. DOD Transportation Regulation 4500.9-R, Part VI, Management 

and Control of Intermodal Containers and System 463L Equipment (September 2009) 

(includes changes through Nov. 29, 2012). U.S. Central Command, CENTCOM Container 

Management Letter of Instruction (CM LOI) (Jan. 15, 2014) (hereinafter cited as 

CENTCOM Container Management Letter of Instruction (Jan. 15, 2014).

11GAO, Determining Performance and Accountability Challenges and High Risks, 

GAO-01-159SP (Washington, D.C.: November 2000). GAO/AIMD-00-21.3.1. GAO 

developed criteria for assessing performance and accountability for an agency’s major 

program and mission areas and management functions in GAO-01-159SP. The criteria 

were developed by considering the requirements of program-specific legislation as well as 

the requirements of management-reform legislation, such as the Chief Financial Officers 

Act of 1990, the Government Performance and Results Act of 1993, the Government 

Management Reform Act of 1994, the Federal Financial Management Improvement Act of 

1996, and the Clinger-Cohen Act of 1996. 
Page 6 GAO-15-114 Defense Logistics

concluded that the container data were sufficiently reliable to present 

select findings, but identified limitations that are discussed later in this 

report. Appendix I provides additional details on the scope and 

methodology.

We conducted this performance audit from February 2013 to November 

2014 in accordance with generally accepted government auditing 

standards. These 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.

Shipping containers are reusable intermodal enclosures or flat, open 

platforms that meet International Organization for Standardization (ISO) 

container standards and are intended to be loaded with cargo and 

shipped on or in a transportation conveyance.12 The containers DOD 

uses are typically 20 to 40 feet long and 8 feet wide, some of which are 

refrigerated for perishable goods.13

The containers DOD has managed in the CENTCOM area of 

responsibility, including in Afghanistan, are owned or leased by DOD; 

owned by coalition partners; owned by contractors supporting DOD; or 

owned by commercial carriers operating under DOD’s Universal Services 

Contract. The Universal Services Contract provides international cargo 

transportation and distribution services using ocean common or contract 

carriers, and offers regularly scheduled commercial liner service for 

DOD uses containers to transport 

equipment and supplies to destinations in support of troops conducting 

military operations worldwide, including Afghanistan. In austere 

environments, DOD also uses containers for many other purposes such 

as providing secure storage for goods and using container walls for force 

protection.

 12The International Organization for Standardization develops voluntary international 

standard product specifications to improve the efficiency of industry and international 

trade. Regarding shipping containers, ISO standards for shipping containers include, for 

example, external, internal, and door dimensions, strength of walls, floors, and ceilings, 

and marking and identification requirements. 

13DOD also uses other types of containers, including some that are less than 20 feet long, 

bulk fuel storage containers, and flat shipping racks.

Background
Page 7 GAO-15-114 Defense Logistics

requirements that may arise in any part of the world. The contract is 

primarily for DOD requirements and applies to services performed in 

peacetime and exigency areas. Contract provisions include detention-fee 

rates, container purchase options and prices, and maximum detention-fee 

accrual periods, among other provisions. When carriers deliver goods 

using their own containers, DOD has a contractually specified number of 

days to return a container before incurring added fees—defined as “freetime” in the contract. After the free-time period ends, DOD accrues daily 

detention fees until the carrier is notified that an empty container is 

available for pickup.14 Under various circumstances, the contract also 

allows DOD to acquire a carrier’s container, either through the payment of 

a maximum amount of detention fees, or through payment of a 

contractually set purchase price after a minimum amount of detention 

fees has been paid.15

As of August 2014, DOD’s container-management system comprises two 

key information management systems—the U.S. Transportation 

Command’s Integrated Booking System/Container Management Module 

and the Army Container Asset Management System—along with the 

persons and organizations using, updating, and managing the two 

systems. The Surface Deployment and Distribution Command and 

CENTCOM use the Integrated Booking System/Container Management 

Module as their container-management system. The system provides 

data on all container ownership types used in theater including 

government-owned or leased, coalition partner-owned, and carrier-owned 

containers in theater and estimates detention costs for containers that are 

not returned to carrier owners prior to the end of the free-time period. The 

Army Container Asset Management System records all containers in 

DOD’s inventory and serves as the official property record for Armyowned containers. From the Army Container Asset Management System, 

personnel can conduct studies on Army container status, location, and 

 14DOD’s Global Container Management Policy defines detention fees as a charge made 

on a carrier conveyance held by or for a consignor or consignee beyond the allowable free 

time for loading or unloading, for forwarding directions, or for any other purpose 

authorized and documented by the consignor or consignee. Fees for detention are in 

addition to all other transportation charges.

15The Universal Services Contract contains an automatic purchase clause under which 

the U.S. government acquires ownership of any carrier-owned container for which the 

government has paid 700 days of accrued detention for any refrigerated container or 350 

days of accrued detention for any other container.
Page 8 GAO-15-114 Defense Logistics

disposition from data entered into the system by its users and data feeds 

from other sources.

Detention fees, purchase prices, and maximum detention-fee accrual 

periods in Iraq and Afghanistan varied, according to the Universal 

Services Contract, depending on the size of a container and whether the 

container is refrigerated. For example, in 2013, detention fees for carrierowned containers ranged from $22 to $127 per day and could accrue 

over periods ranging from 350 days to 700 days, at which point DOD 

would become the de facto owner. Containers could also be purchased 

prior to these maximum periods, but only after a minimum period of 

detention is paid: 60 days for containers shipped under the 2013 

Universal Services Contract or 90 days for containers shipped under 

previous contracts. Purchase prices in 2013 ranged from $2,880 to 

$31,500 depending on the size of a container and whether the container 

was refrigerated. Figure 1 shows detention fees DOD accrued from fiscal 

years 2003 through 2012. Fiscal year 2013 and 2014 data are excluded 

from this figure because detention fees can accrue over a period of 350 to 

700 days; therefore, payment of these fees for containers leased in a 

given fiscal year may extend into subsequent fiscal years. Moreover, until 

a contract is closed out, the contractor may continue to make detentionfee claims.
Page 9 GAO-15-114 Defense Logistics

Figure 1: Detention-Fee Payments for Containers Shipped to Afghanistan and Iraq 

in Fiscal Years 2003 through 2012

Note: Detention fees for fiscal years 2013 and 2014 were not fully known prior to issuance of this 

report because detention fees can accrue over a period of 350 to 700 days. Data were not available 

to separate container-fee payments between Afghanistan and Iraq.

Since the early years of operations in Afghanistan and Iraq, DOD officials 

have made efforts to improve container management in the CENTCOM 

area of responsibility. One way they continue to improve container 

management is by either updating existing or developing new containermanagement policy and guidance. To do so, they incorporated 

recommendations by DOD audit agencies and other organizations aimed 

at improving container management. However, it is uncertain whether all 

of the recommendations have been incorporated into DOD policy as 

appropriate because the department does not have a comprehensive list 

of the recommendations that have been made over the years.

DOD Cannot 

Determine the Extent 

to Which Its Policy 

and Guidance 

Incorporate 

Recommendations to 

Improve Container 

Management in the 

CENTCOM Area of 

Responsibility
Page 10 GAO-15-114 Defense Logistics

Since the early years of operations in Afghanistan and Iraq, DOD officials 

have made efforts to improve container management in the CENTCOM 

area of responsibility. One way they continue to improve container 

management is by either updating existing or developing new container 

management policy and guidance based on recommendations made by 

DOD audit agencies as well as other organizations. Specifically, these 

policy and guidance changes have addressed various aspects of 

container management including: (1) doctrine and planning for the use of 

containers in a contingency environment, (2) leadership’s responsibility 

for container management, and (3) efforts to improve the tracking and 

inventorying of containers.

Doctrinal and planning guidance for Army units with distribution 

responsibilities in the CENTCOM area of responsibility, which includes 

responsibility for container management, is contained in three documents: 

Army Regulation 56-4: Distribution of Materiel and Distribution Platform 

Management, published in March 2007 and revised in September 2014; 

Army Theater Distribution, published in May 2011; and Army Container 

Operations, published in May 2013.16 However, according to Army 

officials, both Army Theater Distribution and Army Container Operations

were informed by a recommendation made in a 2008 Army Audit Agency 

report that container management in a contingency environment be 

integrated into doctrine and planning.17 In addition, Army officials noted 

that these documents also address a 2011 Army Audit Agency 

recommendation that lessons learned about container management for 

ongoing and future contingencies be institutionalized in the contingency 

planning process.18

Leadership’s responsibility for container management in the CENTCOM 

area of responsibility is addressed in the Container Detention 

memorandum signed by both the commander of U.S. Transportation 

 16Army Regulation 56-4, Distribution of Materiel and Distribution Platform Management

(Sept.17, 2014); U.S. Army, Army Theater Distribution, ATTP 4-0.1 (FM 100-10-1) (May 

20, 2011.); and U.S. Army, Army Container Operations, ATP 4-12 (May 10, 2013).

17U.S. Army Audit Agency, Audit of Management of Shipping Containers in Southwest 

Asia – Iraq (Project A-2007-ALL-0081.004), A-2008-0098-ALL (Alexandria, Va.: Apr. 3, 

2008). 

18U.S. Army Audit Agency, Container Management in Iraq—Condition and Contents, A2011-0047-ALL (Alexandria, Va.: Dec. 22, 2010).

DOD’s ContainerManagement Policy and 

Guidance Incorporate 

Some Recommendations 

to Improve Container 

Management
Page 11 GAO-15-114 Defense Logistics

Command and CENTCOM in August 2012.19

The tracking and inventorying of containers in the CENTCOM area of 

responsibility is addressed in the aforementioned CENTCOM Container 

Management Letter of Instruction, initially issued in 2006 according to 

U.S. Transportation Command officials and periodically updated 

thereafter, most recently in January 2014. In this letter, CENTCOM 

emphasizes the necessity for the timely entry of data for all containers 

moving into, within, or out of the CENTCOM area of responsibility; 

stresses the importance of maintaining accurate theater-wide container 

inventories through a robust inventory management program; and details 

the roles and responsibilities of the various DOD organizations that 

constitute the theater container- management structure. According to 

CENTCOM officials, the CENTCOM Container Management Letter of 

Instruction and its periodic updates address concerns raised by Army 

Audit Agency reports from 2005 and 2009 and the Joint Logistics Board’s 

report of 2012 that recommended enhancing and clarifying the authority 

of the theater container-management structure; conducting physical 

inventories of containers in order to better track them; and completing 

According to U.S. 

Transportation Command officials, this memorandum was published as a 

direct result of a recommendation made in a Joint Logistics Board report, 

also published in 2012, that included additional recommendations aimed 

at enhancing senior leaders’ understanding of container-management 

challenges and detention-fee payments and enforcing compliance with 

previously published container-management policy as outlined in 

CENTCOM’s Container Management Letter of Instruction. Specifically, 

the Container Detention memorandum states that compliance with 

CENTCOM’s Container Management Letter of Instruction is mandatory 

and that all subordinate commanders in theater are to ensure that their 

respective units embrace container-management and detention-fee 

reduction goals. Moreover, the Container Detention memorandum states 

that subordinate commanders in the CENTCOM theater should report 

container transactions in order to track the receipt, location, and 

discharge of containers in accordance with procedures also specified in 

the CENTCOM Container Management Letter of Instruction.

 19U.S. Transportation Command Memorandum, Container Detention (Scott Air Force 

Base, Ill. (Aug. 28, 2012)
Page 12 GAO-15-114 Defense Logistics

property-management functions for containers purchased in the 

CENTCOM area of responsibility.20

Notwithstanding DOD’s efforts to improve container management in the 

CENTCOM area of responsibility by either updating existing or developing 

new policy and guidance in response to recommendations made by DOD 

and other organizations, DOD cannot ensure recommendations have 

been addressed in policy and guidance as appropriate. This is because, 

according to DOD officials, no single office or entity within the department 

has comprehensively identified all of the reports and recommendations 

the various DOD and other organizations have made to improve container 

management in the CENTCOM area of responsibility. Standards for 

Internal Control in the Federal Government call for an organization’s 

internal control processes to ensure that the findings of audits and other 

reviews are promptly resolved.21

When we asked key officials from DOD organizations that play some role 

in or have some responsibility for container management to identify what, 

if any, steps had been taken to address recommendations that have been 

made by DOD and other organizations, the officials responded that this 

information was not easily available without extensive work to compile. 

Because DOD could not provide us with a comprehensive list of reports 

and their associated recommendations addressing containermanagement challenges in the CENTCOM area of responsibility, we 

conducted our own literature search and subsequently compiled a list of 

25 reports and reviews issued by DOD and other organizations from 2003 

through 2013. Included in these reviews and reports are 95 

recommendations aimed at improving container management in the 

CENTCOM area of responsibility (see table 1). Although this list may not 

be comprehensive because our search was limited to the period 2003 

through 2013, and DOD had no source or means to corroborate or verify 

what we identified, when we requested that DOD provide us information 

on the steps taken to address the recommendations we did identify, DOD 

 20U.S. Army Audit Agency, Asset Visibility and Container Management: Operation Iraqi 

Freedom, A-2005-0197-ALE (Europe Field Office: July 2005); Audit of the Management of 

Shipping Containers Southwest Asia – Afghanistan (Project A-2007-ALL-0081.005), A2009-0033-ALL (Alexandria, Va.: January 2009); U.S. Transportation Command, 

Container Management Tiger Team Findings and Recommendations (June 2012).

21GAO/AIMD-00-21.3.1. 

DOD Cannot Ensure That 

All Recommendations 

Addressing Container 

Management in the 

CENTCOM Area of 

Responsibility Have Been 

Incorporated in Policy and 

Guidance as Appropriate
Page 13 GAO-15-114 Defense Logistics

provided information on steps taken to address 55 of the 95 

recommendations that we identified. However, DOD did not provide 

answers for the remaining 40 recommendations.22

Table 1: Number of Reports Issued from 2003 through 2013 That Included Recommendations to Improve Shipping-Container 

Management

Organization

Reports issued / 

reviews

Recommendations 

identified Period of issuance

Department of Defense (DOD) audit agencies 20 79 2003–2013

DOD components / other organizations 3 13 2004–2012

GAO 2 3 2007–2011

Total 25 95 2003–2013

Source: GAO analysis of DOD data. | GAO-15-114

Note: Recommendations we identified may not be comprehensive because DOD did not have an 

alternative source or means to corroborate or verify what we identified. Additionally, the same or 

similar recommendations may appear in different reports and therefore may be duplicated.

According to Standards for Internal Control in the Federal Government, 

internal control is an integral part of an organization’s management that 

provides reasonable assurance that operations are conducted effectively 

and efficiently, that financial reporting is reliable, and that applicable laws 

and regulations are complied with. One of the standards of internal 

control is Monitoring, which calls for agencies to assess the quality of 

performance over time and ensure that the findings of audits and other 

reviews are promptly resolved. In this vein, managers are to: (1) promptly 

evaluate findings from audits and other reviews, including those showing 

deficiencies and recommendations reported by auditors and others who 

evaluate agencies’ operations; (2) determine proper actions in response 

to findings and recommendations from audits and reviews; and (3) 

complete, within established time frames, all actions that correct or 

otherwise resolve the matters brought to management’s attention.23

 22For the 55 instances where DOD provided information on steps taken to address the 

recommendations that we identified, DOD officials indicated that actions were taken to 

implement the recommendations, including incorporating changes into DOD’s policy or 

guidance, for 32 of the 55 recommendations.

A

second standard, Information and Communications, states that 

information should be recorded and communicated to management and 

23GAO/AIMD-00-21.3.1.
Page 14 GAO-15-114 Defense Logistics

others within the entity who need it and in a form and within a time frame 

that enables them to carry out their internal control and other 

responsibilities. However, based on DOD’s container-management 

officials’ lack of comprehensive awareness of recommendations 

described previously, DOD cannot reasonably assure that all 

recommendations for the CENTCOM area of responsibility have been 

addressed in policy or guidance, as appropriate. Without a 

comprehensive list, DOD cannot reasonably assure whether it has 

addressed all of the recommendations related to container management 

operations as appropriate in policy or guidance, nor can it reasonably 

assure that policymakers have the information available and incorporate it 

as needed into new and existing container-management policies. DOD 

could use our work as a starting point for identifying additional 

recommendations to improve container-management policy and guidance 

for the next contingency.

Since mid-2012, DOD has taken a number of steps to manage and 

reduce shipping-container detention fees incurred for the untimely return 

of commercial shipping containers used in Afghanistan. However, DOD’s 

ability to manage and reduce container detention fees is limited by 

inaccurate and incomplete data about the number and location of 

containers accruing detention fees.

According to DOD, the department tracks the amount of detention fees it 

accrues each fiscal year and has worked to manage and reduce these 

fees through a variety of efforts. For example, in June 2012, a Joint 

Logistics Board-directed container-management team issued a report that 

included recommendations for improving global container management 

that would reduce detention costs in CENTCOM. Subsequently, in August 

2012, DOD implemented one of the team’s recommendations when the 

commanders of the U.S. Transportation Command and CENTCOM 

issued their joint memorandum—addressed to the military services, the 

Defense Logistics Agency, U.S. Forces Afghanistan, and CENTCOM’s 

component commands—directing them to focus specifically on improving 

DOD Has Taken 

Steps to Manage and 

Reduce ShippingContainer Detention 

Fees in Afghanistan, 

but Its Ability to 

Manage and 

Reduce These 

Fees Is Limited

DOD Has Taken Steps to 

Manage and Reduce 

Shipping-Container 

Detention Fees
Page 15 GAO-15-114 Defense Logistics

container-management operations to reduce detention fees. The joint 

memorandum also established a requirement within the CENTCOM area 

of responsibility that within 15 days of a shipping container’s arrival, 

receiving organizations are to acknowledge receipt of the container, 

unload the container, and notify the responsible carrier that its container 

is available for pickup. In addition, according to the joint memorandum, 

U.S. Transportation Command and CENTCOM developed a set of 

tracking metrics to monitor progress in meeting this requirement.24

Following the collective actions it has taken to manage and reduce 

detention fees, DOD estimated that there would be a significant decrease 

in fees for 2013 and 2014.

Furthermore, in March 2013, U.S. Transportation Command’s 

subordinate organization, the Surface Deployment and Distribution 

Command, developed and began tracking data against containermanagement goals to support the drawdown from Afghanistan, according 

to officials from the organization. The data included the number of 

containers not released for carrier pickup and the number of containers 

accruing detention fees for longer than 3 months. Lastly, in September 

2013, according to CENTCOM officials, CENTCOM formed an assistance 

team in Afghanistan to help operating bases focus on container 

management in order to improve container inventory database accuracy 

and reduce the number of containers, which could reduce detention fees.

25

 24U.S. Transportation Command, Container Detention.

Specifically, DOD estimated that the $57 

million in detention fees paid in 2012 will be reduced to $41 million in 

fiscal year 2013 and to $40 million in fiscal year 2014. DOD officials said 

that they expected the decrease in detention fees because of a 

combination of two factors: (1) a projected reduction in the number of 

containers being shipped into Afghanistan as operations draw down 

there, and (2) a reduction in the average detention fees that will be 

accrued per container resulting from actions DOD has taken to reduce 

and manage those fees. Because of insufficient data, however, according 

to Surface Deployment and Distribution Command officials, DOD could 

not determine the extent to which the expected decrease would be due to 

actions the department has taken in theater to reduce and manage 

25As stated previously, detention fees can accrue over a period of 350 to 700 days. 

Therefore, detention-fee payments for containers leased in one fiscal year may extend 

over multiple fiscal years. Moreover, until a contract is closed out, the contractor may

continue to make detention-fee claims. 
Page 16 GAO-15-114 Defense Logistics

detention fees or the expected decrease would be the result of other 

factors such as there being fewer containers in Afghanistan as a result of 

the drawdown.26 Further, according to Surface Deployment and 

Distribution Command officials, because there is a lag in the time carriers 

submit detention-fee invoices, it is difficult for DOD to determine a reliable 

estimate for detention fees for containers in theater at a given time. The 

officials said that they hope to have more reliable data after (1) operations 

cease in Afghanistan, when remaining detention invoices and requestsfor-equitable-adjustment detention-fee claims are received and 

processed, and (2) the Universal Services Contract is closed out, which 

will not occur until fiscal year 2016 or later.

Although DOD has estimated that there will be a decrease in the amount 

of detention fees it will pay, its ability to manage and reduce detention 

fees for containers subject to them in Afghanistan is limited by incomplete 

and inaccurate data on the number and location of containers in country. 

Moreover, DOD has not assessed contributing factors to determine the 

root causes for its incomplete and inaccurate data.

According to Standards for Internal Control in the Federal Government,

for an agency to run and control its operations, it must have relevant, 

reliable information relating to internal events.27 In this regard, the DOD 

Transportation Regulation specifies that combatant commanders are to 

collect and maintain data on every container in theater.28

 26In June 2011, the United States announced plans to reduce the number of U.S. forces in 

Afghanistan and, by September 2012, had reduced its number by 33,000 troops. 

Concurrently there has been a decrease in the number of containers being shipped to 

Afghanistan and a reduction in the number of operations locations and bases in 

Afghanistan where containers are located. As a result, the number of containers in 

Afghanistan has decreased.

However, 

DOD’s data on the number of carrier-owned containers subject to 

detention fees is incomplete and inaccurate. Without relevant and reliable 

data, DOD’s ability to monitor and reduce detention fees is limited. For 

example, DOD concluded that the total number of containers in DOD’s 

27An event is a process or part of a process occurring in a particular moment and place. 

For example, the delivery of a container to DOD would constitute an event for which an 

agency would need relevant and reliable information. 

28DOD Transportation Regulation 4500.9-R, Management and Control of Intermodal 

Containers and System 463L Equipment.

DOD’s Incomplete and 

Inaccurate ContainerManagement Data Limits 

Its Ability to Manage and 

Reduce Detention Fees 

in Afghanistan
Page 17 GAO-15-114 Defense Logistics

container-management system subject to detention fees were 

understated because the invoices DOD received for the same period 

indicated that there was a greater number of carrier-owned containers in

theater.29

In addition to incomplete data on the number of containers subject to 

detention, the DOD container-management system also does not contain 

accurate data on the location of all shipping containers in Afghanistan. 

CENTCOM’s container-management policy sets as a goal the 

establishment of accountability for containers in theater, which includes 

accurate recording of the location of each container into the containermanagement system.

Specifically, using data from DOD’s container-management 

system on the number of carrier-owned containers used in the 

CENTCOM area of operations (including in Afghanistan), container 

managers estimated that detention fees for fiscal year 2011 would be 

about $23 million. However, DOD received detention-fee invoices totaling 

about $84 million for fiscal year 2011, about 3.7 times higher than 

estimated, which represents approximately 5,200 containers that DOD 

could not account for. According to Surface Deployment and Distribution 

Command officials, improvements in data feeds and user data entry have 

been made over the past 4 years as they have worked to resolve this 

discrepancy but have not yet fully done so. Nonetheless they believe that 

the discrepancy arose primarily from inaccuracies in inventory data. 

Without accurate inventory data to validate invoices, DOD is at risk for 

being overbilled, which happened during fiscal years 2010 and 2011 

according to Surface Deployment and Distribution Command officials. 

Specifically, investigations by the Surface Deployment and Distribution 

Command and others beginning in 2010 led to recouping costs for 

incorrect carrier-shipment billings, resulting in $3.9 million and $9.0 million 

in detention-fee refunds to DOD for fiscal years 2010 and 2011, 

respectively.

30

 29DOD’s determination was based on data queries from its container-management system 

for September 2010 through October 2013 for the number of carrier-owned containers in 

Afghanistan subject to detention fees compared to detention-fee invoices received for the 

same period.

However, data for DOD shipping containers in 

Afghanistan on 4 separate days, from April 2013 through the end of 

December 2013, showed that containers with unknown locations ranged 

from 14 percent to 25 percent of all containers in Afghanistan. Figure 2 

30CENTCOM Container Management Letter of Instruction (Jan. 15, 2014). 
Page 18 GAO-15-114 Defense Logistics

illustrates the portion of containers in Afghanistan with known and 

unknown locations on October 31, 2013.31

Figure 2: Comparison of DOD Containers in Afghanistan with Known and Unknown 

Locations on October 31, 2013

Moreover, our additional analysis indicated that, over the period 

September 2010 through December 2013, 7,707 individual carrier-owned 

containers had unknown locations recorded in the container-management 

system with 572 of those individual shipping containers accruing 

detention fees for 1 year or more. Without accurate location data, DOD’s 

ability to locate, empty, and return those carrier-owned shipping 

containers is limited, and detention fees, therefore, can continue to 

accrue unabated until reaching the maximum allowed by contract—

approximately twice the purchase price of the container.

DOD has identified several procedural weaknesses in the management of 

containers in theater that may affect the accuracy and completeness of 

container-management data. According to Surface Deployment and 

Distribution Command officials, one procedural weakness is that 

containers are not always being recorded in theater when received. 

Specifically, the officials stated that the procedures for verifying the 

 31We selected October for this figure because it followed the end of the fiscal year, and 

was neither the highest nor lowest value for the dates for which we had data. 
Page 19 GAO-15-114 Defense Logistics

receipt of a container at a base in Afghanistan do not require a receiving

unit representative to sign directly for shipping containers upon arrival 

because operations at bases can be quite extensive, and waiting for a 

receiving unit representative to arrive at the delivery point32 would create 

or exacerbate backlogs. Therefore, according to Surface Deployment and 

Distribution Command officials, the person manning the delivery point

when the container arrives signs for it, although that person has no 

responsibility for entering any data into the DOD container-management 

system. As a result, container managers may be unaware of containers 

delivered to their areas of responsibility and not learn that such containers 

are accruing detention fees until after DOD receives a bill from the carrier 

for the detention fees. CENTCOM’s container management policy 

specifies that within 48 hours of receiving a container the receiving unit 

should record the event in DOD’s container-management system.33 In 

addition, Standards for Internal Control in the Federal Government state 

that events such as the receipt of goods (e.g., shipping containers and 

their contents) should be promptly recorded to maintain their relevance 

and value to management in controlling operations and making 

decisions.34

 32According to Surface Deployment and Distribution Command officials, container delivery 

varies depending on the base location, and may occur, for example, at a central receiving 

and shipping point within a base, or at a base gate. 

However, our analysis of DOD’s container-management 

system data and carrier delivery data for the end of each month in 2013 

showed that DOD had not recorded in the container-management system 

about 16 percent of the carrier-owned containers delivered and received 

in Afghanistan. Moreover, according to U.S. Transportation Command 

officials, without records of receipts, DOD does not always have complete 

documentation to confirm whether or not delivery dates and resulting 

detention fees claimed by the carrier are correct, and, as a result, has 

accepted unsupported delivery claims and billings for detention fees. Until 

the location of a container is determined, DOD may purchase containers 

that are known to be lost to avoid further detention payments or it may 

continue to pay the detention fees up to the maximum amount allowed by 

contract—ranging from approximately $3,200 to $47,500 depending on 

the type of container—at which time, DOD becomes the owner of that 

container.

33CENTCOM Container Management Letter of Instruction.

34GAO/AIMD-00-21.3.1.
Page 20 GAO-15-114 Defense Logistics

In addition, Surface Deployment and Distribution Command officials have 

identified a variety of other procedural weaknesses that they stated led to 

carrier-owned containers not being recorded in the containermanagement system, which may also affect the accuracy and 

completeness of data. Specifically, they identified instances where the 

following occurred:

• Containers were shipped into the theater outside of the DOD 

container-management system. For example, a carrier delivers a 

container to the theater before it is recorded in DOD’s containermanagement system. This situation may occur when a unit orders 

items that are shipped directly from a supplier or manufacturer instead 

of through an intermediary military supply activity.

• Container records were closed before the container was returned to 

the specified pickup location without prior approval from the carrier for 

this change. For example, a unit in theater unloads a container at a 

location other than the original delivery point and records the 

container as ready for carrier pickup without the carrier’s agreement to 

the alternative location. Recording the container as ready for carrier 

pickup causes DOD’s container-management system to disregard the 

container as subject to detention fee accrual. However, without carrier 

agreement to the alternative pick up location, detention fees continue 

to accrue under the terms of the Universal Services Contract.35

• Container records were closed while the container was in use. For 

example, an in theater container manager may mistakenly conclude 

that because a container is no longer in a unit’s possession, it has 

been returned to a carrier. The container manager, therefore, 

designates the container record as inactive in DOD’s containermanagement system. However, the container may still be in DOD’s 

possession and subject to detention fees.

• Containers were recorded incorrectly as government-owned 

containers. For example, a container manager in theater with a large 

volume of containers may mistakenly code a carrier-owned container 

as a DOD container. The DOD container-management system does 

 35In its technical comments, DOD noted that if a carrier’s driver picks up a container from

a location that is different from that delivered, then detention fees would stop at that point, 

but DOD did not provide data on how often this has happened in the past or state the 

likelihood of it happening in the future.
Page 21 GAO-15-114 Defense Logistics

not consider these incorrectly coded containers as subject to 

detention fees, however detention fees continue to accrue.

While DOD has identified the procedural weaknesses above that may 

affect the completeness and accuracy of container-management data and 

has, according to Surface Deployment and Distribution Command 

officials, researched container data and taken other steps to resolve most 

of these instances, the department has not assessed the extent to which 

these weaknesses have affected the data. For example, the Joint 

Logistics Board-directed container-management team recommended 

more automated reporting to significantly reduce manually inventorying 

containers, thereby improving the accuracy of inventory data.36 In 

response, DOD contracted for the development of automated technology 

for the recording of shipping containers as they enter and exit military 

installations and, according to DOD officials, expects to complete an initial 

evaluation of the selected technology after the end of fiscal year 2014. 

According to DOD officials, the technology is intended to provide 

irrefutable proof of a container’s movement, work without reliance on 

satellite tags, and supplement or even replace the need for human 

manual entry. However, DOD has not identified the root cause or causes 

for the inaccurate inventory data that this recommendation and the 

selected technology are intended to address, which is critical if the 

department is to correct the procedural weaknesses that contribute to 

inaccurate and incomplete data. Further, according to Surface 

Deployment and Distribution Command officials, no DOD office has 

identified the root causes of the other procedural weaknesses discussed 

above or developed a corrective action plan with corrective measures to 

address the root causes. In our process for determining agencies’

programs at high risk due to their greater vulnerabilities to fraud, waste, 

abuse, and mismanagement or the need for transformation to address 

economy, efficiency, or effectiveness challenges, we developed criteria 

stated in our November 2000 report, Determining Performance and 

Accountability Challenges and High Risks, which found that one step that 

agencies can take to help resolve their programs’ performance and 

accountability challenges is to develop a corrective action plan that 

includes identifying root causes and effective solutions.37

 36U.S. Transportation Command, Container Management Tiger Team Findings and 

Recommendations.

For container 

37GAO-01-159SP.
Page 22 GAO-15-114 Defense Logistics

management, such a corrective plan would contain corrective measures 

intended to help develop effective solutions for better locating and 

confirming receipt of containers and verifying detention invoices as a 

means to manage and reduce detention fees in current and future 

contingencies. According to these criteria, for improving federal agency 

performance and accountability, agencies can help resolve a program’s 

performance and accountability challenges by developing a corrective

action plan that identifies root causes and effective solutions and provides 

for completion of corrective measures in the near term.38 Further, 

Standards for Internal Control in the Federal Government state that an 

agency’s procedures are among the control activities that help ensure 

actions are taken to address risks and are an integral part of an entity’s 

implementing and accountability for stewardship of government resources 

and achieving effective results.39

 38

One reason DOD has not identified the 

root cause or causes for the procedural weaknesses that contribute to 

inaccurate or incomplete container-management data nor developed a 

corrective-action plan with effective solutions that provide for completion 

of corrective measures, according to Surface Deployment and Distribution 

Command officials, is that the responsibility for handling containers in 

Afghanistan is dispersed among CENTCOM, U.S. Transportation 

Command, and U.S. Forces–Afghanistan and its subordinate units. 

According to the officials, their command, which is a subordinate element 

of U.S. Transportation Command, has attempted to improve the 

completeness and accuracy of container-management data and to 

identify root causes for its inaccuracy and incompleteness by focusing on 

areas that fall within their responsibility, such as providing training on 

managing containers and on assessing and improving the data systems. 

However, they also noted that other factors affecting the completeness 

and accuracy of container-management data fall outside of the Surface 

Deployment and Distribution Command. According to Surface 

Deployment and Distribution Command officials, other than the 

command’s attempts, no other DOD office has assessed root causes for 

the procedural weaknesses identified in this report or developed a 

corrective-action plan to assess the procedural weaknesses and 

determine their root causes.

GAO-01-159SP. 

39GAO/AIMD-00-21.3.1. 
Page 23 GAO-15-114 Defense Logistics

According to Surface Deployment and Distribution Command officials with 

global container management responsibilities, complete data on the 

number of carrier-owned containers, including which containers are 

accruing detention fees, would help DOD container managers achieve a 

reduction in these fees. Until DOD assesses its procedural weaknesses, 

identifies the root causes for those weaknesses, and develops and 

implements a corrective-action plan to address them, the department is 

limited in its ability to manage and reduce detention fees. Further, 

because it will not have the information it needs to correct the deficiencies 

in the data to better locate and confirm receipt of containers and verify 

detention invoices until it does so, DOD will not have reliable data to 

assess how well its efforts to manage and reduce detention fees are 

working currently and in future contingencies.

The management of shipping containers has been a long-standing 

challenge for DOD, a challenge that is particularly acute during 

contingency operations and one that has been exacerbated in 

Afghanistan given the harsh conditions that exist there. Recently, the 

Deputy Secretary of Defense’s Global Container Policy and the August 

2012 memo signed by the commanders of the U.S. Transportation 

Command and CENTCOM demonstrate that DOD’s top leadership 

recognizes the challenges container managers face in managing 

containers and the need for reducing detention fees during this most 

recent conflict. However, in order to proactively and successfully improve 

future container-management operations and prevent the accumulation of 

detention fees, DOD would benefit by being fully apprised of all 

recommendations made by DOD audit agencies and other organizations 

thus far and determining which actions would potentially resolve 

container-management challenges. DOD could use our work as a starting 

point for identifying additional recommendations to improve containermanagement policy and guidance for the next contingency. In addition, 

until DOD assesses its procedural weaknesses, identifies the root causes 

for those weaknesses, and develops and implements a corrective-action 

plan to address them to help improve the quality of its containermanagement data, it will be difficult for the department to determine how 

best to improve its container-management operations, including the 

reduction of detention fees.

Conclusions
Page 24 GAO-15-114 Defense Logistics

To help DOD to improve the overall management of shipping containers 

for current and future contingencies, we recommend that the Secretary of 

Defense take the following three actions.

To more fully incorporate recommendations into its policy and guidance 

and to ensure that improvements to container management will be 

sustained for future contingencies, we recommend that the Secretary of 

Defense develop a comprehensive list of recommendations made by 

DOD agencies and other organizations, and make the information 

available for policymakers to incorporate, as appropriate, into new or 

existing container-management policy and guidance. DOD could use our 

work as a starting point for this assessment.

To help ensure DOD’s container-management system has more complete 

and accurate data, and DOD is better positioned to assess progress in 

managing containers to reduce detention fees, we recommend that the 

Secretary of Defense direct the Commander CENTCOM to

• identify the root cause or causes for the procedural weaknesses in the 

handling of containers and the extent to which they contribute to the 

incomplete and inaccurate recording of container-management data in

theater, and

• develop and implement a corrective action plan with effective 

solutions for the root causes identified that provide for completion of 

corrective measures.

We provided a draft of this report to DOD for review and comment. In 

written comments, DOD concurred with one of the three 

recommendations and partially concurred with the two other 

recommendations. DOD’s comments are summarized below and 

reprinted in appendix II. DOD also provided technical comments on the 

draft report, which we incorporated as appropriate.

DOD concurred with the first recommendation that the Secretary of 

Defense develop a comprehensive list of recommendations made by 

DOD agencies and other organizations, and make the information 

available for policymakers to incorporate, as appropriate, into new or 

existing container-management policy and guidance. DOD has 

requested that we provide a listing of the 95 recommendations identified 

during this review to use as a starting point for its assessment, to which 

we agreed.

Recommendations for 

Executive Action

Agency Comments 

and Our Evaluation
Page 25 GAO-15-114 Defense Logistics

DOD partially concurred with the second recommendation that the 

Secretary of Defense direct the Commander CENTCOM, to identify the 

root cause or causes for the procedural weaknesses in the handling of 

containers and the extent to which they contribute to the incomplete and 

inaccurate recording of container-management data in theater. DOD 

stated that it concurred with the recommendation, but added that 

CENTCOM is responsible for theater container management and control 

in its area of responsibility. DOD also stated that CENTCOM will 

coordinate with U.S. Transportation Command to the extent that specific 

theater actions affect overall global container management. We initially 

drafted the recommendation to both CENTCOM and the U.S. 

Transportation Command in order to ensure that action would be taken 

from both commands; however, we agree with DOD that CENTCOM is 

responsible and that coordination with U.S. Transportation Command to 

the extent that specific theater actions affect overall global container 

management is appropriate. Therefore, we modified the recommendation 

accordingly. 

DOD partially concurred with the third recommendation that the Secretary 

of Defense direct the Commander CENTCOM, to develop and implement 

a corrective action plan with effective solutions for the root causes 

identified that provide for completion of corrective measures. DOD stated 

that it concurs with the recommendation, but also stated that 

implementing the recommendation is a CENTCOM responsibility. 

Further, DOD stated that only CENTCOM may direct military Service 

component commands to take specific actions in the CENTCOM area of 

responsibility. DOD added that if resolution of the issues requires actions 

beyond CENTCOM’s purview, then CENTCOM will refer specific actions 

to the Joint Staff for assistance in obtaining resolution with other 

commands and organizations. We initially drafted the recommendation to 

both CENTCOM and the U.S. Transportation Command in order to 

ensure that action would be taken from both commands; however, we 

agree with DOD that CENTCOM is responsible and that coordination with 

the Joint Staff for assistance in obtaining resolution with other commands 

and organizations is appropriate. Therefore, we modified the 

recommendation accordingly.
Page 26 GAO-15-114 Defense Logistics

We are sending copies of this report to the appropriate congressional 

committees, the Secretary of Defense, the Commanders for CENTCOM 

and the U.S. Transportation Command, and other interested parties. In 

addition, this report is available at no charge on GAO’s Web site 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. GAO staff who made key contributions to this 

report are listed in appendix III. 

Cary B. Russell, Director

Defense Capabilities and Management
Appendix I: Scope and Methodology

Page 27 GAO-15-114 Defense Logistics

To assess the extent to which Department of Defense (DOD) policy and 

guidance incorporate recommendations that address containermanagement challenges in the U.S. Central Command’s (CENTCOM) 

area of responsibility, we reviewed DOD-wide, combatant command, and 

service-specific policy and guidance pertaining to container management 

to develop our understanding of container-management operations and 

roles and responsibilities. To identify recommendations made by DOD 

audit agencies and other organizations that addressed containermanagement challenges, we researched websites and databases and 

contacted officials as necessary from the following audit agencies: Army 

Audit Agency, Naval Audit Service, Air Force Audit Agency, DOD Office 

of Inspector General, Defense Contract Audit Agency, Defense Contract 

Management Agency, Special Inspector General for Iraq Reconstruction, 

Special Inspector General for Afghanistan Reconstruction, and GAO. We 

interviewed DOD logistics and container-management officials from the 

Office of the Deputy Assistant Secretary of Defense for Transportation 

Policy, U.S. Transportation Command, CENTCOM, the U.S. Army, the 

U.S. Marine Corps, Surface Deployment and Distribution Command, and 

the Defense Logistics Agency to discuss challenges with and efforts to 

improve container management, and identify additional reports or studies 

with findings and recommendations involving container-management 

issues. During this process, we observed that these recommended 

corrective actions were generated over time and concluded that 

development of such actions may be an ongoing effort.

To identify findings and recommendations relating to containermanagement issues potentially affecting DOD operations in CENTCOM’s 

area of responsibility, we reviewed the reports and studies for the 10-year 

period 2003 through 2013—the period DOD began tracking detention 

fees for operations in Iraq and Afghanistan through the completion of field 

work on this objective of our review. The recommendations we identified 

may not be comprehensive because DOD did not have an alternative 

source or means to corroborate or verify what we identified. Additionally, 

the same or similar recommendations may appear in different reports and 

therefore may be duplicated. We analyzed the relevant recommendations 

to identify the organizations responsible for implementation and 

categorized the recommendations to determine patterns and repetition 

over time. We discussed the listing of recommendations with DOD 

container-management officials to determine how the department 

addressed the findings and recommendations. We then requested the 

department provide us with the status of the recommendations we had 

identified to determine whether actions were completed or implemented. 

We reviewed DOD policy and guidance pertaining to container 

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

Page 28 GAO-15-114 Defense Logistics

management to determine the extent that the categories of 

recommendations we identified were reflected in them. We also reviewed 

the recommendations status updates DOD provided to identify instances 

where DOD stated that recommendations had been incorporated into 

container-management policy and guidance. We compared DOD’s 

inclusion of recommendations addressing container-management 

challenges into its policy and guidance documents against criteria for 

recording and communicating important information to management as 

contained in the Information and Communication, and Monitoring, 

standards in Standards for Internal Control in the Federal Government.

1

To determine the extent to which DOD managed and reduced container 

detention fees, we met with officials from the Office of the Deputy 

Assistant Secretary of Defense for Transportation Policy, U.S. 

Transportation Command, CENTCOM, U.S. Army, U.S. Marine Corps, 

Surface Deployment and Distribution Command, and the Defense 

Logistics Agency to develop an understanding of how DOD accrues and 

pays detention fees, and manages shipping containers to reduce the 

accumulation of detention fees. We observed the processes and 

procedures by which invoices for detention fees are received, reviewed, 

and paid. Also, we observed demonstrations of the DOD system used to 

track and manage shipping containers used in the CENTCOM area of 

responsibility and collected comprehensive listings of containers and 

associated data for each container captured in these listings. We 

observed demonstrations of DOD’s two key systems used in container 

management for Afghanistan (the U.S. Transportation Command’s 

Container Management Module and the Army Container Asset 

Management System), collected information on the systems’ structure 

and data content, and requested and collected various reports produced 

in queries on 4 separate days, from April 2013 through December 2013, 

for complete data on the number of containers in theater that officials 

conducted at our request. From the U.S. Transportation Command’s 

Container Management Module we then collected and analyzed complete 

data sets for all shipping containers recorded for Afghanistan to 

understand the densities and usages of shipping containers in 

Afghanistan. This included determining locations where containers were

recorded and the ratios of carrier-owned containers to government-owned 

 1

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

(Washington, D.C.: November 1999). 
Appendix I: Scope and Methodology

Page 29 GAO-15-114 Defense Logistics

containers; and identifying containers without recorded geographic 

locations, the length of time carrier-owned containers had been in 

Afghanistan, and the ratios of containers recorded as empty to those with 

contents or occupants.

In Afghanistan, we met with U.S. Forces–Afghanistan officials and various 

container control officers identified by officials from the Surface 

Deployment and Distribution Command to discuss shipping-container 

management and the accuracy of data recorded in the Container 

Management Module. We also collected all available end-of-month DOD 

listings—from September 2010 through December 2013—of carrierowned shipping containers subject to detention-fee accruals for analysis. 

We selected September 2010 because it was the first month for which 

DOD had available end-of-month data. We concluded with December 

2013 because it was the cutoff date for the analyses that we had planned 

to conduct. We summarized and discussed our initial analysis with 

officials from the Surface Deployment and Distribution Command to 

ensure accurate interpretation of the data collected. We compared our 

observations, data we collected, and our analyses with Standards for 

Internal Controls in the Federal Government and DOD regulations such 

as the Defense Transportation Regulation and CENTCOM’s Container 

Management Policy Letter of Instruction that specify the need to 

accurately and timely record data that has an effect on detention fee 

accrual.2

 2

We also assessed DOD’s efforts to improve its management of 

container data against best practices for improving federal agency 

performance and accountability found in Determining Performance and 

Accountability Challenges and High Risks, and Standards for Internal 

Control in the Federal Government, which address risks and 

accountability for achieving effective results. GAO developed the criteria 

for assessing performance and accountability for an agency’s major 

program and mission areas and management functions by considering 

the requirements of program-specific legislation as well as the 

requirements of management-reform legislation, such as the Chief 

Financial Officers Act of 1990, the Government Performance and Results 

Act of 1993, the Government Management Reform Act of 1994, the 

Federal Financial Management Improvement Act of 1996, and the 

Clinger-Cohen Act of 1996.

GAO/AIMD-00-21.3.1.
Appendix I: Scope and Methodology

Page 30 GAO-15-114 Defense Logistics

We assessed the reliability of the data by reviewing related 

documentation, interviewing knowledgeable officials, and testing the data 

for obvious errors and completeness. We concluded the data were 

sufficiently reliable to present selected findings on the completeness and 

accuracy of the numbers and locations of shipping containers subject to 

detention fees, but identified limitations that are discussed in this report.

We conducted this performance audit from February 2013 to November 

2014 in accordance with generally accepted government auditing 

standards. These 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 31 GAO-15-114 Defense Logistics

Appendix II: Comments from the

Department of Defense
Appendix II: Comments from the

Department of Defense

Page 32 GAO-15-114 Defense Logistics
Appendix II: Comments from the

Department of Defense

Page 33 GAO-15-114 Defense Logistics
Appendix III: GAO Contact and Staff 

Acknowledgments

Page 34 GAO-15-114 Defense Logistics

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

In addition to the contact named above, key contributors to this report 

include Guy LoFaro, Assistant Director; Jim Ashley; Tracy Barnes; 

Richard Burkard; Virginia Chanley; Grace Coleman; Larry Junek; Anne 

McDonough-Hughes; Mary Catherine Hult; Carol Petersen; Pauline 

Reaves; and John Strong.

Appendix III: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments

(351805)
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