Department of Homeland Security
 

TSA Management and Oversight at Honolulu 


International Airport 


OIG-12-128 September 2012
 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Washington, DC 20528 / www.oig.dhs.gov 

SEP 27 2012 

MEMORANDUM FOR:	 John W. Halinski 

Deputy Administrator 

Transportation Security Administration 

FROM:	 Anne L. Richards 

Assistant Inspector General for Audits 

SUBJECT:	 TSA Management and Oversight at Honolulu International 

Airport 

Attached for your action is our final report, TSA Management and Oversight at Honolulu 

International Airport. We incorporated the formal comments from the Transportation 

Security Administration in the final report. 

The report contains four recommendations aimed at improving airport screening 

operations. Your office concurred with all recommendations. Based on information in 

your response to the draft report, we consider recommendations 2 and 3 resolved and 

open. Once your office has fully implemented the recommendations, please submit a 

formal closeout letter to us within 30 days so that we may close the recommendations. 

The memorandum should be accompanied by evidence of completion of agreed-upon 

corrective actions and of the disposition of any monetary amounts. 

Recommendations 1 and 4 remain unresolved and open. As prescribed by the 

Department of Homeland Security Directive 077-1, Follow-Up and Resolutions for the 

Office of Inspector General Report Recommendations, within 90 days of the date of this 

memorandum, please provide our office with a written response that includes your 

(1) agreement or disagreement, (2) corrective action plan, and (3) target completion 

date for each recommendation. Also, please include responsible parties and any other 

supporting documentation necessary to inform us about the current status of the 

recommendation. Until your response is received and evaluated, the recommendations 

will be considered open and unresolved. 

Consistent with our responsibility under the Inspector General Act, we are providing 

copies of our report to appropriate congressional committees with oversight and 

appropriation responsibility over the Department of Homeland Security. We will post a 

redacted version of the report on our website. 
 

 

 

 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Please call me with any questions, or your staff may contact Mark Bell, Deputy Assistant 

Inspector General for Audits, at (202) 254-4100. 

Attachment 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Executive Summary ...................................................................................................... 1
 

Background ................................................................................................................. 2
 

Results of Audit ............................................................................................................ 5
 

Effects of Changes to Screening Procedures Not Fully Evaluated ........................ 5
 

More Direct Supervision of Screening Operations, Better Supervisory Guidance,
 

and Training Needed ......................................................................................... 8
 

Inadequate Staffing and Need for Equipment at Affected Location................... 11
 

Recommendations ......................................................................................... 15
 

Management Comments and OIG Analysis ...................................................... 16
 

Appendixes 

Appendix A: Objectives, Scope, and Methodology......................................... 20
 

Appendix B: Management Comments to the Draft Report ............................ 23
 

Appendix C: Representatives Mica and Chaffetz Request Letter .................... 29
 

Appendix D: Review of Training .................................................................... 31
 

Appendix E: Review of Performance Indicators and Disciplinary Actions........ 33
 

Appendix F: Staff Involved in Security Failure ............................................... 40
 

Appendix G: HNL Airport Configuration......................................................... 41
 

Appendix H: Types of Checked Baggage Screening Searches.......................... 42
 

Appendix I: Major Contributors to This Report............................................. 43
 

Appendix J: Report Distribution................................................................... 44
 

 OFFICE OF INSPECTOR GENERAL

Department of Homeland Security 

Table of Contents 

www.oig.dhs.gov OIG-12-128
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security

Abbreviations 

DHS Department of Homeland Security 

EDS Explosive Detection System 

ETD Explosive Trace Detection 

FSD Federal Security Director 

FY fiscal year 

HNL Honolulu International Airport 

OIG Office of Inspector General 

SOP standard operating procedure 

TSA Transportation Security Administration 

TSO Transportation Security Officer 

TSM Transportation Security Manager 

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 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security

Executive Summary 

Representatives John Mica and Jason Chaffetz requested a review to determine why a 

portion of the Transportation Security Administration’s (TSA) screener workforce at 

Honolulu International Airport did not perform critical transportation security screening 

of baggage. The request came after TSA investigated allegations of improper screening 

of checked baggage at the airport and took disciplinary and administrative actions. The 

objective of our audit was to determine whether TSA ensured that Transportation 

Security Officers complied with baggage screening procedures at Honolulu International 

Airport. 

Although ignoring security procedures is never justified, Transportation Security Officers 

at one location in Honolulu International Airport did not screen all checked baggage as 

required during the last few months of 2010. The responsibility for screening the 

baggage belongs to the individual Transportation Security Officers, but this situation 

might not have occurred if TSA —

Developed changes in screening procedures comprehensively and then 

thoroughly evaluated the effects of such changes; 

Supervisors provided better oversight of Transportation Security Officers and 

baggage screening operations; and 

Provided screening operations at the affected location with adequate staff and 

screening equipment in a timely manner. 

Without ensuring that baggage is screened as appropriate, TSA risks the safety of the 

traveling public by allowing unscreened baggage on passenger aircraft. 

We made four recommendations to TSA that, when implemented, should assist the 

agency with developing and managing changes to security procedures. The 

recommendations should also help TSA provide more effective oversight of airport 

screening operations. TSA concurred with the four recommendations. 

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Department of Homeland Security

Background 

TSA protects the Nation’s transportation systems to ensure freedom of movement for 

people and commerce. TSA reports that its vision is to set the standard for excellence in 

transportation security through its people, processes, and technology. 

As part of TSA’s mission, all individuals, accessible property, and checked baggage must 

be screened using the screening methods contained in TSA’s standard operating 

procedures (SOPs). TSA’s Checked Baggage Screening Standard Operating Procedures 

describe uniform procedures and standards for screening baggage to deter, detect, and 

prevent the carriage of any prohibited items, such as explosives, incendiaries, or 

weapons, onboard aircraft. TSA periodically modifies its SOPs to adjust to the current 

threat environment, the addition of new equipment, or passenger concerns. 

TSA primarily uses the Explosive Detection System (EDS) or Explosive Trace Detection 

(ETD) to screen checked baggage. 

EDS screening of checked baggage requires Transportation Security Officers 

(TSOs) to place checked baggage in a machine to screen it by x ray for prohibited 

items. EDS screening of checked baggage is mandatory at locations where the 

equipment is available. 

ETD screening of checked baggage relies on manual procedures combined with 

technology to identify small amounts of explosives. ETD screening requires TSOs 

to

 TSOs swab baggage and 

place the swab in a unit that uses ETD technology to analyze the content for
 

potential explosive residue. 

Prior to January 2010, TSA’s SOP for using ETD required that 

receive (testing the 

of checked bags 

(40/40/20 

protocol). TSA explained that although the 40/40/20 protocol was initially effective and 

efficient for random and unpredictable screening, the changing threat environment 

warranted new procedures. Appendix H contains a detailed description of TSA’s 

checked baggage screening searches. 

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 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security

TSA’s Office of Security Operations explored options to replace the 40/40/20 protocol 

with a procedure that improved the probability of detection while maintaining an 

acceptable level of efficiency using TSA staffing allocation standards. TSA decided to

 and use a new ETD method that required a 

1

 Selectee bags would continue 

to be screened using procedures. 

Beginning in January 2010, TSA required TSOs to 

of checked bags 

when using the ETD screening 

methodology at all airports, including Honolulu 

International Airport (HNL). The new SOP allowed 

use, at times, of alternate screening procedures 

(mitigation procedures). Mitigation procedures 

enable staff to use alternate procedures for timely 

screening during specific, short-term, special 

circumstances, such as unexpected increases in 

the volume of checked baggage. Authority was 

delegated to the Federal Security Director (FSD) at 

an airport to implement such procedures for 15­

Mitigation Procedures allow for 

screening of bags by: 

baggage that is swabbing four 

checked bags at a time taking

of each bag. 

There may only be a total of 

before the sample is analy ed. 

Using certified canine teams. 

Source: TSA 

minute increments to decrease the security risks associated with excess baggage. 

In December 2010, a confidential source notified TSA officials and provided video 

evidence showing some TSOs failing to follow required screening procedures at the 

Overseas Terminal (Lobby 4) screening location at HNL. Although some employees 

adhered to the agency’s screening procedures, others circumvented these procedures 

and cleared bags for transport without the required screening. 

Among other things, the evidence showed TSOs A notice of inspection is a 

opening bags, placing notices of inspection inside, document TSOs place inside 

and transporting them back to the airline without checked baggage indicating the 

baggage has been opened for 

screening them. The videos also showed TSOs inspection by TSA.

marking baggage as “cleared” before screening, Source: TSA 

 is a special requirement for individuals selected by a computer-assisted passenger screening 

syst

1

em or another process as determined and approved by TSA. 

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 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security

 a cart loaded with baggage, and screening baggage by swabbing only the 

In response to the allegations of screening violations, TSA’s Office of Inspection 

performed an investigation between December 31, 2010, and March 23, 2011. The 

investigation team interviewed 191 employees and reviewed documentation and video 

evidence. Although one TSO admitted to circumventing screening procedures as early 

as January 2010, the investigation focused only on the period between September and 

December 2010. TSA took personnel actions against employees who did not properly 

screen checked baggage during the last few months of 2010 in the Overseas Terminal 

(Lobby 4). 

In June 2011, Representative John Mica and Representative Jason Chaffetz requested a 

review to determine why a portion of TSA’s screener workforce at HNL failed to perform 

critical transportation security screening. The Representatives requested that the Office 

of Inspector General (OIG) provide “a complete TSA's National Deployment

analysis of the failure of TSA’s oversight and Force deploys Transportation 

Security Officers to support airport supervision of screening operations, protocols, screening operations during 

and procedures,” including corrective and emergencies seasonal demands

or other circumstances requiring disciplinary actions. They also requested that we more staffing resources than are review performance evaluations, guidance, regularly available.

Source: TSA training requirements, and use of the National
 

Deployment Force. The Representatives’ letter is
 

in appendix C; additional information responding to their questions is in appendixes D,
 

E, and F.
 

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 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security

Results of Audit 

Although ignoring security procedures is never justified, TSOs at one location in HNL did 

not screen all checked baggage as required during the last few months of 2010. The 

responsibility for screening the baggage belongs to the individual TSOs, but this 

situation might not have occurred if TSA — 

Developed changes in screening procedures comprehensively and thoroughly
 

evaluated the effects of such changes; 


Supervisors provided better oversight of TSOs and baggage screening operations;
 

and
 

Provided screening operations at the affected location with adequate staff and 


screening equipment in a timely manner.
 

Without ensuring that baggage is screened as appropriate, TSA risks the safety of the 

traveling public by allowing unscreened baggage on passenger aircraft. 

Effects of Changes to Screening Procedures Not Fully Evaluated 

TSA’s fragmented process of developing changes to screening procedures and 

not fully evaluating the effects of new procedures may have contributed to the 

screening violations at HNL. 

Developing Changes to Screening Procedures and Evaluating Effects 

TSA had a fragmented and inconsistent process for developing and evaluating 

changes to its SOP for baggage screening. TSA relied on different numbers and 

locations of airports when studying proposed changes to the SOP. TSA had 

difficulty providing a comprehensive document or centralized point of contact to 

explain the studies and analysis to support decisions driving this and other 

changes to SOPs. Nor did TSA have a comprehensive document that showed 

whether the procedural changes would have an adverse effect on unique 

airports, such as HNL, which has a high volume of checked baggage and densely 

packed boxes that require screening. 

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Table 1: Airports Evaluated in Pilot Studies* 

No. Category 2007 2008 2009 2010 

1 X √ 

2 X √ 

3 I √ √ 

4 I √ √ √ 

5 I √ √ √ √ 

6 II √ 

7 II √ √ 

8 II √ 

9 II √ √ √ 

10 II √ 

11 III √ 

12 III √ 

13 III √ 

14 III √ 

15 III √ 

16 III √ 

17 IV √ 

18 IV √ 

19 IV √ 

20 IV √ 

21 IV √ 

22 IV √ 

23 IV √ 

Source: OIG based on TSA information. 

*TSA classifies the Nation’s airports into one of five categories (X, I, II, III, and IV) 

based on various factors such as the number of annual takeoffs and landings. In 

general, Category X airports have the largest number of passengers boarding 

aircraft and Category IV airports have the smallest number. 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security

Between 2007 and 2010, TSA headquarters conducted four pilot studies on the 

effects of various ETD protocols on checked baggage screening. However, these 

studies did not contain sufficient data and analysis to guide procedural changes 

nationwide. As shown in table 1, TSA was not consistent with the airports 

tested. According to TSA officials, the inconsistencies were due to changes in the 

equipment on hand and other factors. 

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 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Between 2007 and 2010, TSA conducted four pilot studies of ETD protocols: 

�	 In a 2007 study, TSA reviewed 10 Category X through IV airports using 

four different screening ETD protocols. The results showed that the 

average search time to screen of checked baggage 

was 320 seconds per bag; using the 40/40/20 protocol took an 

average of 161 seconds per bag. 

� In a 2008 study of 13 Category I through IV airports, data was collected 

on ETD screening with
 

The results showed that Category I 

airports had problems screening the 

checked baggage in a timely manner. 

The report recommended providing 

EDS machines to two airports with 

high numbers of passengers to relieve 

them of ETD screening. 

�	 In a 2009 study, TSA tested an 

additional five Category I and II 

ETD Protocols Studied 

1 

2 

3 

4 

Source: TSA 

airports. The report concluded that implementing ETD using the 

protocol increased screening time over using the 40/40/20 protocol. 

However, when implementing the protocol in January 2010, TSA 

could not demonstrate how it used this information. 

� In a 2010 study conducted in April and May after implementing the 

protocol, TSA tested it at four Category I, II, and IV airports. 

Although results were limited, they showed that those airports were 

meeting the average screening time and recommended ending additional 

data collection. TSA did not test a Category X airport during this study. 

At the time of the change to the Checked Baggage Screening SOPs in January 

2010, HNL and were the only Category X 

airports with locations using on checked 

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 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security

baggage. TSA did not test these airports in any of the four pilot studies. 

Therefore, TSA did not know the effects of changes to the SOPs on its largest 

airports. 

Although none of the pilot reports thoroughly explained TSA’s methodology for 

selecting airports for the studies, TSA indicated that it focused on airports that 

relied heavily on ETD-only screening. Additionally, although TSA officials 

explained that they tried to be consistent in their choices of airports, only 1 of 

the 23 airports was tested in all four pilot studies, as shown in table 1. Our 

statistician reviewed the study information provided by TSA and concluded that 

TSA documentation did not address a specific methodology that TSA used to 

select airports for pilot testing. 

More Direct Supervision of Screening Operations, Better Supervisory Guidance, 

and Training Needed 

The TSOs’ decision not to follow screening procedures could have been due in 

part to limited direct supervision. Also, clearer guidance on direct observation of 

screening operations and better training of supervisors might have addressed 

this situation. 

Direct Supervision 

Screening procedures were circumvented, in part, because of Supervisory TSOs’ 

limited direct supervision of employees at HNL. TSA management at HNL did not 

ensure that screening managers and supervisors were regularly present, 

observing operations, and performing all responsibilities required by TSA 

management directives and SOPs. 

Although the level of supervision of checked baggage screening operations is not 

recorded or measured, our video review, TSA’s investigation report, and 

employee interviews showed TSA management provided varying levels of 

supervision. Some TSOs believed management and direct oversight was 

sufficient, but the majority stated that management, including Lead TSOs and 

Supervisory TSOs, provided occasional, little, or no direct supervision. For 

example: 

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 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security

One Transportation Security Manager (TSM) said that he observed the 

Lead TSO, Supervisory TSO, and another manager spending too much 

time in the office and not managing staff at the baggage screening 

locations. 

One Supervisory TSO said that TSMs were not involved at all at baggage 

screening locations. 

One Supervisory TSO confirmed that there was no local policy for direct 

supervision. The Supervisory TSO would have liked more direct contact 

with the TSMs and did not believe managers spent enough time at 

screening locations. 

Supervisory Guidance 

TSA has directives and procedures on management and oversight 

responsibilities, but they do not include clear guidance on direct supervision of 

screening operations, and thus allow different interpretations and 

implementation. TSA’s directives and procedures include its Screening 

Management SOP and the Performance Accountability and Standards System 

Management Directive No. 1100.43-1 and User Guidance. 

TSA’s Screening Management SOP includes staffing guidelines, duties, and 

responsibilities to ensure that checked baggage screening meets statutory 

requirements. According to this SOP, the Supervisory TSO is responsible for 

implementing security screening standards at all screening locations. The SOP 

further explains that a Supervisory TSO must be present at each screening 

location open for operation or designate a Lead TSO to act on his or her behalf. 

The SOP identifies more than 40 Supervisory TSO tasks to ensure that each 

screening location is operating properly. These tasks include the following: 

Monitoring TSO and Lead TSO performance; 


Maintaining the proper staffing level at each screening location;
 

Ensuring that TSOs are knowledgeable about all SOPs; 


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Department of Homeland Security

Correcting improper screening or behavior; and
 

Ensuring that Notice of Inspection cards are properly used and controlled.
 

Although the SOP includes Supervisory TSO responsibilities and requirements for 

completing duties, it does not include specific metrics, leaving the 

responsibilities and requirements open to interpretation. For example, the SOP 

requires Supervisory TSOs or designated Lead TSOs to monitor TSO performance, 

monitor all screening activities, and ensure compliance with all applicable SOPs. 

The SOP also requires them to correct improper or faulty application of 

screening procedures to ensure effective, vigilant, and courteous screening. 

However, rather than include more specific details on oversight requirements, 

the SOP focuses on screening equipment operation, safety concerns, and 

opening and closing of screening locations. 

The Performance Accountability and Standards System TSA Management 

Directive No. 1100.43-1 and User Guidance includes criteria for evaluating TSOs’ 

and Lead TSOs’ technical proficiency, competencies, readiness for duty, training 

and development, and collateral duties. However, it does not contain means of 

measuring or evaluating the quality or quantity of direct supervision. For 

Supervisory TSOs and Screening Managers, this directive has similar criteria and 

provides criteria for supervisory accountability factors. Specifically, it includes a 

team-based measure that holds Supervisory TSOs and TSMs accountable for 

their direct reports in “Readiness for Duty” and “Training and Development.” 

Supervisory Training 

TSA provides Supervisory TSOs with training courses focused on general 

supervisory skills, but does not provide sufficient training on the quality and 

quantity of observation and supervision; or how often managers, Supervisory 

TSOs, and Lead TSOs should be physically present to observe screening 

operations. We attribute this training deficiency to the need for supervisory 

requirements in TSA’s oversight-related guidance. 

The Supervisor Technical Training course provides Supervisory TSOs and Lead 

TSOs with general supervisory skills to manage checkpoints and checked baggage 

screening locations. The training course discusses key topics such as Supervisory 

TSO job functions, communication, situational awareness, and managing 

screening operations. For example, the definition of situational awareness 

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 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security

includes understanding current conditions, recognizing potential hazards, 

planning, decision-making, understanding consequences of loss, and being 

proactive. The course provides information on managing multiple security 

incidents at checkpoints and checked baggage screening locations, but does not 

thoroughly address balancing Supervisory TSO administrative functions with 

direct observation. 

Before TSA required Supervisory TSOs to take the Supervisor Technical Training 

course, it required them to take COACH! Training. This training helped 

Supervisory TSOs build on existing leadership skills with tools for checkpoint and 

checked baggage locations, but it did not directly address oversight and 

observation. TSA also offers TSMs a course—Leading People and Managing 

Operations—to provide general supervisory skills to manage responsibilities and 

challenges at checkpoints and checked baggage screening locations. 

Although these three courses discuss key topics such as working with 

stakeholders, communication, and screening operations, TSA training could give 

more guidance to Supervisory TSOs and managers on how best to provide 

leadership presence at screening locations to ensure that TSOs are complying 

with screening procedures. 

Inadequate Staffing and Need for Equipment at Affected Location 

TSA management at headquarters and HNL did not provide the staffing and 

more efficient equipment needed for screening operations at the affected 

location. Data was available for analysis, but TSA management at headquarters 

used a limited selection of information to predict and prepare for staffing 

demands. Furthermore, TSA management at HNL did not allocate staff 

appropriately to handle the volume of checked baggage that needed screening. 

Although requested, TSA headquarters did not provide the affected screening 

location with more efficient equipment to screen checked baggage, causing local 

TSA management to implement temporary solutions and mitigation procedures. 

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 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security

Use of Data for Allocating Staff 

TSA headquarters was aware that airports with high annual numbers of 

passengers boarding aircraft had difficulty screening checked baggage in a timely 

manner using ETD screening protocols. Yet TSA did not optimize its use of the 

available information and data to predict and prepare for staffing demands. 

TSA’s pilot testing of new ETD protocols did not include significant testing of 

Category X airports, which have the largest number of passengers boarding 

aircraft. 

TSA’s Office of Security Operations conducted a 2008 pilot study of 13 airports, 

which included testing of three Category I airports, using an ETD protocol of 

and 

Following the study, TSA issued a memo proposing that Category I airports revert 

to the 40/40/20 protocol “in an effort to maintain operational flow and meet 

departure schedules.” 

At Category I airports, between 1.25 million and 5 million passengers board 

aircraft annually, whereas at Category X airports such as HNL, which were not 

tested in the study, more than 5 million passengers board annually. Because TSA 

did not test its ETD protocol at Category X airports, it did not know 

whether these larger airports had difficulties screening checked baggage using 

the proposed new ETD screening protocol. 

According to TSA management at HNL, 

some passengers who travel to Asian 

nations check very large boxes, called 

Balikbayan boxes (see exhibit 1). 

Measuring 18"x 18"x 24", these 

densely packed boxes are much larger 

than the 8"x 12"x 20" bag TSA used to 

estimate the length of time needed to 

screen using ETD. There was no study 

to evaluate the effect of these boxes 

under the changed SOPs. 

Exhibit 1: Balikbayan Boxes 

Source: OIG 

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 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security

Local TSA management explained that they frequently shifted staff from other 

checked baggage screening locations to assist the affected screening location 

during peak times. On daily reports, screening managers documented staffing 

levels by specific screening location, but we could not determine how TSA used 

these reports to address the staffing problem, such as finding trends in the 

number or frequency of TSOs moved. Without tracking these staffing decisions, 

TSA management at HNL could not predict when such staffing would be needed 

in the short term or provide TSA headquarters with useful information for future 

staffing decisions. 

Mitigation Procedures 

TSA allowed airports to use mitigation procedures when using ETD screening 

under the new protocol. According to TSA, the FSD at an airport may 

implement mitigation for 15-minute increments to decrease the security risks 

associated with excess baggage. The decision to implement mitigation 

procedures places direct responsibility on the FSD for deviating from standard 

checked baggage screening protocols. This option recognizes that timely 

screening cannot be conducted at all times, and it may create a 

misunderstanding among TSOs on the acceptability of applying alternate 

screening practices. 

The affected screening location at HNL documented using mitigation procedures 

30 times from January 13 through February 11, 2010. We did not find 

documentation that mitigation procedures were used after February 11, 2010; 

however, we noted that HNL screened an increasing volume of checked baggage 

with the same staffing allocation at the affected screening location. HNL 

management implemented additional actions, such as adding ETD machines or 

transporting baggage to other screening locations with EDS equipment, but 

these options were burdensome to TSOs. 

To expedite the screening process for unexpected high-volume baggage needing 

to be screened, TSA allows airports to use various levels of screening and to 

intermittently use mitigation procedures under specific circumstances. Although 

bypassing security measures is never justified, these practices may have led 

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Department of Homeland Security

some TSOs to believe that was not 

always possible, and that it was acceptable to not always perform such searches. 

Equipment 

TSA headquarters did not provide HNL with the requested EDS screening 

equipment in a timely manner. HNL requested an EDS machine for the screening 

area in August 2008 because of safety concerns at the affected location. The 

request noted that safety is the over arching concern related to this request. 

More specifically, the check-in area of Lobby 4 is very congested because many 

of the flights are scheduled around the same time, causing the baggage to 

accumulate in a confined area. This causes a safety issue for the passengers as 

well as the Officers. 

TSA headquarters confirmed receipt of HNL’s request and added it to an 

unfunded requirements list. However, a prior OIG audit showed that new and 

used equipment was stored in a warehouse awaiting delivery to airports for 

more than 1 year at the time HNL was requesting the EDS equipment.2 

In 2009, TSA headquarters informed HNL that the equipment would arrive in 

June 2010, 18 months after it was requested. TSA officials later explained that 

there were delays with the system integration contractor, pushing estimated 

delivery and installation to December 2010. The equipment arrived in December 

2010, as the TSA Office of Inspection investigation began. 

Without the more efficient EDS equipment, TSA management at HNL 

implemented labor-intensive interim options to ensure that all baggage was 

screened. For example, HNL established a pod of four additional ETD screening 

stations in the affected screening location. Local TSA management also 

instructed TSOs to transport baggage to another area approximately 500 feet 

away for EDS screening, which TSOs explained was physically demanding. TSOs 

had to load carts, navigate through crowds of passengers, unload and screen the 

2

 DHS OIG Audit Report, Management of the Transportation Security Administration's Logistics Center, 

OIG-10-14, November 2009. 

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 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security

baggage, and then return the loaded carts to the original area. See appendix G 

for a diagram of this location. 

Conclusion 

TSA does not know the extent to which baggage was not screened during 2010 

at HNL, placing the safety of the traveling public at risk by allowing unscreened 

baggage on passenger aircraft. There is no acceptable justification for TSOs to 

bypass their security mission; however, TSA allowed various levels of screening 

and intervals of mitigation that TSOs could easily misinterpret as meaning that 

screening was not always possible or needed. 

To ensure compliance with its SOPs, TSA should fully evaluate the effects of 

changes to them. TSMs and Supervisory TSOs need to provide sufficient direct 

oversight to ensure that all baggage is screened according to approved 

procedures. Finally, TSA needs to ensure that airports have the appropriate 

staffing and equipment to conduct screening in accordance with SOPs. 

Recommendations 

We recommend that the Transportation Security Administration Deputy 

Administrator: 

Recommendation #1: 

Create and document protocols to ensure that sufficient information is gathered 

and used for thorough analysis when deciding to modify standard operating 

procedures. These protocols should be well documented and ensure 

comprehensive, transparent, and logical approaches with detailed support, while 

allowing for flexibility to address urgent threats. 

Recommendation #2: 

Revise the position descriptions to clarify the roles and responsibilities for 

checked baggage supervisors and managers and define the expectations for 

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Department of Homeland Security

direct supervision. This should ensure that assigned staff are performing 

screening duties in accordance with all standard operating procedures. 

Recommendation #3: 

Ensure that supervisors and managers are trained on their responsibility and 

accountability to ensure that all screening operations are performed as required. 

Recommendation #4: 

Develop and implement performance metrics to evaluate the supervision of 

checked baggage areas as part of supervisory performance plans and 

evaluations. These metrics should include frequent direct observation of 

baggage screening activities. 

Management Comments and OIG Analysis 

TSA provided comments to the draft of this report. A copy of the response in its 

entirety is included in appendix B. TSA also provided technical comments and 

suggested revisions to sections of the report. When appropriate, we made 

changes to reflect the suggested revisions. 

According to its response to the draft report, TSA agreed with our 

recommendations to improve the agency’s management and oversight of its 

security screening operations. TSA had concerns with the report’s conclusion 

and evidence that the screening violations at HNL Lobby 4 might not have 

occurred if TSA developed changes to its screening procedures more 

comprehensively and fully evaluated the effects of such changes. TSA further 

asserted that perceived shortcomings in the process of evaluating changes to 

checked baggage screening procedures did not cause TSOs to decide to 

circumvent those procedures. 

Our report recognizes that ignoring security procedures is never justified, and 

individual TSOs are responsible for screening baggage. However, we maintain 

that a more comprehensive approach to revising screening procedures may have 

helped TSA reduce the need for and use of mitigation procedures and would 

have ensured that all affected airports were considered. 

www.oig.dhs.gov 16 OIG-12-128
 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

We reviewed the documentation that TSA provided demonstrating the agency’s 

data collection effort. Although this effort lasted for several years, TSA only 

tested the proposed ETD screening procedures in two Category X airports in one 

2007 study, and HNL was not one of those two airports. Additionally, TSA did 

not re evaluate any additional Category X airports in subsequent pilot studies of 

this change to the SOPs. Without such data, the agency cannot be certain 

whether the manner in which the SOPs were developed was related to the HNL 

officers’ failure to follow the SOPs. Further, we maintain that allowing the use of 

mitigation procedures demonstrates that TSA recognized changes to the SOPs 

might be a problem for some airports. 

TSA also asserted that we did not provide evidence to support our conclusion 

that mitigation procedures affected baggage screening, and that we ignored 

credible evidence in TSA’s investigation. We reviewed both TSA’s Report of 

Investigation and video evidence, and we agree that TSOs did not conduct the 

required screening. TSA’s Report of Investigation, as well as our interviews, 

showed that TSOs revealed the violations began after January 2010, when the 

SOPs changed, not prior to the revisions. TSOs at HNL knew that mitigation 

procedures were used frequently once the protocol was initially 

implemented, and they had to screen an increasing amount of checked baggage 

at the affected location. For these reasons, officers could have inferred that TSA 

airport management considered mitigation acceptable. 

In its response, TSA further noted that HNL was the only location at which 

procedures were not followed. However, the agency did not provide evidence to 

support this assertion, nor did it demonstrate it reviewed all airports. In fact, 

had the confidential source not provided evidence to TSA, the agency might have 

remained unaware of the violations at HNL. 

Finally, TSA is responsible for knowing the extent to which baggage is not 

screened and ensuring the safety of the traveling public. 

TSA Response to Recommendation #1: TSA concurred with the recommendation. 

The agency agreed it should improve its process to develop, evaluate, and 

www.oig.dhs.gov 17 OIG-12-128 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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document changes to its screening procedures. TSA anticipates implementing 

the new process by June 30, 2013. 

OIG Analysis: This recommendation will remain open and unresolved until TSA 

provides a more detailed corrective action plan and a copy of the approved 

process. 

TSA Response to Recommendation #2: TSA concurred with the 

recommendation and has taken steps to implement corrective action. TSA 

conducted a job analysis study and reviewed job duties, responsibilities, and 

competencies for Supervisory TSOs, Lead TSOs, and TSOs. TSA plans to use the 

results of the study to update position descriptions. TSA expects the revised 

position descriptions to be completed by December 31, 2012. 

OIG Analysis: This recommendation is resolved, but will remain open until TSA 

provides the results of the job analysis study and the revised position 

descriptions. 

TSA Response to Recommendation #3: TSA concurred with the 

recommendation and has begun to implement the recommendation. In July 

2012, TSA launched a 2-week training course titled, “Essentials of Supervising 

Screening Operations.” The course provides Supervisory TSOs with both 

technical and leadership training to address integrity, responsibility, and TSA’s 

mission and vision. TSA expects that the agency’s 4,400 Supervisory TSOs will 

complete the training by February 2014. Additionally, TSA plans to expand its 

training portfolio for managers, Supervisory TSOs, Lead TSOs, and other levels of 

field leadership. 

OIG Analysis: This recommendation is resolved, but will remain open until TSA 

provides the curriculum for the “Essentials of Supervising Screening Operations” 

and evidence that its Supervisory TSOs have completed the training. 

TSA Response to Recommendation #4: TSA concurred with the 

recommendation and has begun to implement the recommendation. TSA 

chartered an Integrated Project Team to identify specific metrics that will allow 

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TSA managers nationwide to more effectively monitor baggage screening 

operations. 

OIG Analysis: TSA’s planned actions address the recommendation. It will 

remain open and unresolved until TSA provides the Integrated Project Team 

charter and related reporting requirements and metrics. 

www.oig.dhs.gov 19 OIG-12-128
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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Appendix A 

Objectives, Scope, and Methodology 

The Department of Homeland Security (DHS) Office of Inspector General (OIG) was 

established by the Homeland Security Act of 2002 (Public Law 107-296) by amendment 

to the Inspector General Act of 1978. This is one of a series of audit, inspection, and 

special reports prepared as part of our oversight responsibilities to promote economy, 

efficiency, and effectiveness within the Department. 

The objective of our audit was to determine whether TSA ensured TSOs were complying 

with baggage screening procedures at HNL. We conducted this audit in response to a 

request by two members of Congress: Representative John Mica, Chairman of the 

Committee on Transportation and Infrastructure; and Representative Jason Chaffetz, 

Chairman of the Subcommittee on National Security, Homeland Defense, and Foreign 

Operations, Committee on Oversight and Government Reform. The Representatives 

questioned why a portion of the TSA screener workforce at HNL failed in their 

performance of critical transportation security screening responsibilities. 

To answer our objective and respond to the Congressmen, we interviewed officials and 

personnel from the following offices at TSA headquarters: 

Office of Security Operations;
 

Office of Security Capabilities;
 

Office of Inspection;
 

Office of Human Capital;
 

Office of Professional Responsibility; and 


Office of Training and Workforce Engagement.
 

We interviewed HNL airport operator staff, TSA officials, TSMs, and all levels of TSOs. 

We attempted to meet with all 48 individuals involved in the security system failure, 

including those suspended and terminated. Only 23 of the 48 individuals were available 

or willing to meet. The 48 individuals included 3 members of the FSD’s staff, 2 TSMs, 

4 Supervisory TSOs, 6 Lead TSOs, and 33 TSOs. The 23 individuals we met with included 

1 member of the FSD’s staff, 1 TSM, 2 Supervisory TSOs, 1 Lead TSO, and 18 TSOs. 

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We reviewed TSA’s Report of Investigation and related personnel actions. We reviewed 

video evidence included in the investigation files and made direct observations of the 

screening location. We analyzed SOPs for checked baggage and screening management 

issued between April 2009 and March 2011. 

We reviewed TSA documentation for staffing allocations and checked baggage 

throughput, requests for additional staffing and equipment, and costs associated with 

the use of the National Deployment Force. 

Using IDEA software, we randomly selected a statistically valid sample of 194 out of 680 

TSOs at HNL and reviewed their training files for October 2009 through March 2011. 3 

We reviewed TSA’s National Training Plan for TSOs, Lead TSOs, and Supervisory TSOs 

from the timeframe under review and selected three training courses per quarter to 

review. We also reviewed three one-time training courses that were relevant to the 

checked baggage security incident at HNL. We reviewed a total of 21 training courses. 

(See appendix D.) 

We used the same statistically valid sample size to review TSO performance evaluation 

files from fiscal year (FY) 2009 through FY 2011. We reviewed disciplinary files for 

January 2009 through September 2011. We looked at these files to determine whether 

TSOs met performance criteria and whether they had disciplinary action taken 

associated with checked baggage screening. (See appendix E.) 

In addition to the statistically valid sample, we reviewed the performance evaluations, 

disciplinary files, and training files for the 43 TSOs involved in the security system failure 

as identified by TSA’s Office of Professional Responsibility. 

We conducted this performance audit between August 2011 and February 2012 

pursuant to the Inspector General Act of 1978, as amended, and according to generally 

accepted government auditing standards. Those standards require that we plan and 

perform the audit to obtain sufficient, appropriate evidence to provide a reasonable 

basis for our findings and conclusions based upon our audit objectives. We believe that 

3

 Given a population of 680 TSOs, a 90 percent confidence interval, 5 percent sampling error, and 50 

percent population proportion, the statistically valid sample size is 194 TSOs. 

www.oig.dhs.gov 21 OIG-12-128
 

 

 

 

 

 OFFICE OF INSPECTOR GENERAL 

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the evidence obtained provides a reasonable basis for our findings and conclusions 

based upon our audit objectives. 

www.oig.dhs.gov 22 OIG-12-128
 

 

 

OFFICE OF INSPECTOR GENERAL 

 Department of Homeland Security

Appendix B 

Management Comments to the Draft Report 

us. Ikpoo.r'ru.m' or Hun,".,," Scw,-J.y 

601 South I:tb Stn:~t 

'lm~"m . V., 10:)~~ 

Transportation 

Security 

AdIninistration 

AtE 31 2IIIZ 

INFORMATION 

MF.MOR AN Ol JM FOR: Anne L. Richards 

Assistant Inspector General/or Audits 

U.S. Department of Homeland Security (DHS) 

FROM: Juhn S. P istol\:: ~ f. .. Adminis1rator 

SUBJECT: TSA Management and O\'cn;ight (Jl Honolulu international 

Airport - n~itive Seo;;udty h(forma/iotl 

orG Project No. ll-1 40-AUD·TSA 

Thi !> memorandum constitutes the Transportation Security Administratio n 's (TSA) response to 

the DI-IS Oflicc of the Inspector General (O IG) draft report entitled, TSA Management and 

Oversight at Honolulu Inlernaliomll Airporl - Sensitive Sc(."urity Information, O IG ProjCl:t No. 

11 -140-AUD-TSA. 

Rack ground 

As DHS OIG describes in Ihe report. TSA primarily uses either Explosives Detection Systems 

(EDS) or Explosives Trace Detection (ETO) to screen cheeked baggage. EDS screening requires 

Transportation Sel:urity Officers (TSOs) to place c hecked baggage in a machine that uses x-ray 

to screen for explosives and other p rohibited items. Em screening requires TSOs to manually 

swab pi:UIs o f lhe bags. am.! anal y£c lIu::: swabs fo r lrm;1:: amuunts of I::xrlusivcs n:::siuuc. 

Prior to January :Wl 0, "SA's Chec ked Baggage Screen in Standard U cratin' Procedures SOP) 

for ETD re uired that f checked bags receive 

(4 A OI2 protoco). 

www.oig.dhs.gov 23 OIG-12-128
 

 OFFICE OF INSPECTOR GENERAL 

 Department of Homeland Security

2 

In 

I I 

screen bEl s in Lobby 4. Consequentl y, TSOs at Lobby 4 were required to 

":::::;.::::::;:~ unless they transported the bags 10 another lobby area within the 

equipped with EDS technology. 

In Decemher 20 1 0 , a L:OnfiUen li<:l1 source ntlLifit.:d T SA nfficials thai Sllme J-fN L TSO s wert! 

clearing checked baggage for transport on a commercial passenger aircraft without cond'ucl:in,g 

the required screening. TSA's investigation into the allegation revealed that 

several months many employees working at HNL Lobby 4 failed to follow 

for ETO screening of checked baggage. More than 40 TSOs. Lead TSOs (L' 

Supervisory TSOs (STSO) submitted sworn statements to TSA investigators that, taken together, 

described widespread and frequent failures by TSA employees working the morni ng shift in 

Lobby 4 to follow the screening protocol. HNL officers admitted to TSA investigators that the 

SOP viol ations induded marking checked hags as "clear" and sending them ontn aimlanes 

without any screenin Th~ officers also admitted 10 conducting onIY ..... ______ --' 

instead of the mandated by the SOP. 

TSA ultimately took disc iplinary action against more thun 40 I-fNL officers for failing to conduct 

required screening, and against two Transportation Security Managers (TSM) and three members 

of the Federal Security Director's (FSD) staff for careless or negligent perfonnance of their 

duties. Disciplinary action ranged from 14-day suspension to removal from the Agency. 

In June 2011, Congressman John Mica and Congressman Jason ChafTetz requested that DHS 

Q1G conduct a review to detennine why a portion ofTSA's HN L screening workforce failed to 

perform critical transportation securi ty screening. The Congressmen asked for "a complete 

analysis of the failure ofTSA 's oversight and supen:ision of baggage and passenger screening 

operations, protocols, and procedures at HNL." 

DHS OIG conducted its review and analysis between August 2011 and February 2012, and has 

provided TSA with its dmft repan, TSA Management and Oversight nl f/rm n/u/u rnrernational 

Airport (DIG Project No. 11- t40-AUD-TSA). Overall, DHS OIG concluded that the 

responsibility for performing required security duties rests with individual employees, but that 

Agency factors also contri buted to the security fa ilure at HNL. The contributory fac tors 

identified by OHS OIG in volved the oversight ofTSOs, the training of"STSOs, the development 

and management of changes to screening procedures, stafting of the security screening 

workforce. and the de ployment of security tec hnology hardware. 

Discussiun 

TSA concurs with OHS OIG's recommendations to improve TSA·s manage.ment and oversight 

of its security screening operati ons. As discussed furthc:r below. TSA has already begun 

implementing some of DHS OIG's recommendations. While TSA agrees with DHS OrG's 

www.oig.dhs.gov 24 OIG-12-128
 

 

 

OFFICE OF INSPECTOR GENERAL 

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3 

recommendations for improving rraining, management, oversight, and the process for testing and 

evaluating SOP changes. we have several concerns with DJ-IS OIO's concl usions in the draft 

report. 

TSA disagrees with DHS OIG's claim that the screening violations at HNL Lobby 4 morning 

shift might not have occurred if TSA developed changes in screening procedures more 

comprehensively and fu lly evaluated the effects of such changes. The manner in which the SOPs 

were developed had noth ing to do with the HNL officer's failure to properl y follow the SOP. 

TSA 's investig.ation revea led Ihm Checked Baggage Screening SOP vinlatinns hecame almust 

normal practice in HNL Lobby 4, and at times some HNL officers were not screening any bags 

at all. The willful nature of the officers' violations and the lack of suffi cientl y diligent 

management oversight. does not support the conclusion that the situation at HNL Lobby 4 could 

have been prevented by (l more streamlined, better documented, process tor evaluating SOP 

changes. 

TSA provided documentation to DHS OIG that demonstrated TSA 's complex and 

comprehensive data collection and analysis effort conducted over a ptoriod of several years at a 

number of diffe rent airports prior to implementing the _ protocol. TSA agrees that 

improvements may be made in this area and has agreed to implement DHS OIG's 

recommendation. I Jowever. TSA does not agree that any perceived shortcomings in the process 

for evaluating changes to TSA's screening procedures caused the officers to make the decision 

not to l:llmpl y with TSA'~ SOP. As DHS OIG notes in the dran repllrt, TSA's investiga tion 

reverucd that from September to December 2010, violations of the Checked Baggage SCfl-'Cning 

SOP had become almost normal practice at HNL Lobby 4. IfTSA's process for implementing 

SOP changes was a factor in the ongoing screening failures. it would be expected that such 

ongoing failures would have been seen at other aillJorts and that did not occur. lfthere were 

identifiable problems with implementing Ihe screening protocols at HNL Lobby 4 as the result of 

its configuration those problems should have been raised up through the chain of supervision for 

remediation. 

TSA also disagrees with DHS OIG's conclusion that the avail ability of checked ba gage 

mitigation procedures could have easily led some TSOs to believe that screenin ' of 

checked baggage was not always possible or necessary. Mitigation procedures are peffilitted to 

account for unpred ictable and unique circumstances where adhering to the standard protocols 

could result in additional security and safety issues. TSA has longstanding limits and tight 

controls for check.ed baggage mitigation and TSOs arc aware that such actions may only bc used 

in limited situations under specific circumstances, The DHS OIG draft 

evidence 10 support the claim that the ex j.\lm!'!i.cll!lii1i!,~ Q(L~~""'!ill flI.'-!!d 

"may have led some TSOs to believe not 

always possible, and that it was 

TSA first established a process for all owing alternative or mitigation procedures for checked 

baggage screening in 2005 to address special circumstances, such as unexpected checked 

baggage volume. TSA's SOP clearly provides that mitigation procedures can only be used under 

" specitic. shun-term, spec ial circumstances" not as a mailer or routine screening ope:rations. 

www.oig.dhs.gov 2� OIG-12-128
 

 

 

OFFICE OF INSPECTOR GENERAL 

 Department of Homeland Security

4 

Mitigation proct:dur~s may only he authorizt!u by an FSD or their designee. and cannot be 

approved by anyone below the position of Assistant FSD tor Screening (AFSD-S). ,'\Iso, 

mitigation procedures are on ly used in 15-minute intervals, and each use must be documented 

and reported to TSA I Icadquarters. 

DHS 010 nut on ly failed lo o ITer evidentiary support for its c[)nciusion about the impact or 

checked baggage mitigation procedures, they ignored the most credible evidence in TSA's 

investigation. TSA 's investigation contained sworn statements of more than 40 TSOs, LTSOs, 

and Supervisory TSOs who admitted to knowingly violating TSA's screening procedures and 

clearly demonstrates that there was no ambiguity about the screening requirements at HNL 

Lobby 4. 

Conclusion: 

TSA appreciates the opportunity to provide feedback to lJHS OlG on its draft findings and 

recommendations. 

DHS OIG provided four recommendations for TSA and our comments follow each 

recommendation: 

Rt=cummendaiion #1: Crt:'ale and document protoculs tu e ns ure tha t suflident inform<Jliofl is 

gathered and used for thorough analysis when deciding to modify standard operating procedures. 

These protocols should be w~H documented and ensure comprehensive, transparent, and logical 

approaches with detailed support, while allowing flex ibility to address urgent threats. 

TSA concur ... TSA agrees that it shou ld improve its process for developing, evaluating, and 

documenting changes to its screening procedures. TSA also apprec iates that DHS OIG 

recognizes that this process should remain flexible to allow the agency to address urgent threats 

and vulnerabilities. TSA anticipates implementing this flew process by June 30, 2013. 

Recommendation #2: Revise the position descriptions to clarify the roles and responsibilities 

for checked baggage supervisors and managers and defi ne the expectations for direct 

supervision. This should ensure that assigned staff are performing screening duties in 

accon.lwH.;e with all stam.larrl opemting, proct=dun:=:s. 

TSA concurs. TSA has already taken steps to implement this recommendation. As pan o f a 

comprehensive job analysis study, TSA recently conducted a thorough review of job duties. 

responsibilities, and competencies for STSOs, LTSOs, and TSOs. The results of this study are 

sl:heouleo to be released by September 30, 2012. TSA anti cipates updati ng the positi on 

descriptions of these positions, while clearly deli neating the role and oversight responsibility of 

STSOs, including checked baggage STSOs. The revised position descriptions are expected to be 

completed by December 31. 2012. 

www.oig.dhs.gov 26 OIG-12-128
 

 

 

OFFICE OF INSPECTOR GENERAL 

 Department of Homeland Security

5 

In addition, TSA pl ans to review the position descriptions for TSM, Deputy AFSD, AFSDs, 

AFSD·S. Ar:SD-MS. DFSO and foSD in 2013 to ensure that supervisory responsibilities arc 

c learly articulated. This update should be completed by August 31,20 13. 

Recommendation #3: Ensure that supervisors and managers are trained on their responsibility 

and accountability to ensure that a ll screenin g operations are performed as required. 

TSA concur.). TSA has already taken steps to implement this recommendation. In October 

2011 , TSA implemented a new c()mpeTency requirement for all screening employee performance 

plnns. titled "Application of Standard Operating Procedures. " This competency is defined as an 

employee's ability to retain and implement knowledge ofal! applicable SOPs related to their 

position and requires that STSOs hold themselves and their subordi nates accountable for 

acquiring, demonstrating, maintaining, implementing, and applying proper screening-related 

knowledge and skills; including the appropriate use ofreehnology and other tonls to perfoml 

routine nnd non-routine assignments in accordance with SOPs, directives, and other polic ies. 

In July 2012, TSA launched a new training course titled 'Essentials of Supervising Sc reening 

Operations'. This 2-week course is specifically designed to help STSOs establish a true 

leadership presence at the checkpoint and checked baggage screening locations by providing 

them the tools they need to understand their leadership strengths, as we ll as how to use their 

strengths to effecti vely eva luate TSO on-the-job performance and take correcti,,'e actions as 

nccdell, to include coaching and mentoring. This l:ourse also provides STSOs wilh LCl:hnical 

training to review Dnd support thc security screening measures they arc responsi ble. for carrying 

out, as well as administrati ve training so they have an opportunity to review the roles and 

responsibili ties for themselves and their officers and identi fy areas where improvements can be 

made. The goal afthis training is to establ ish a cadre afSTSOs that take responsibil ity tor the 

critical role they have in the successful accomplishment of TSAs mission. The training 

addresses integrity, responsibility. core values as well as TSA 's mission and vision, so they are 

all operating from the same basic platform. This training is required far all current and newly 

se lt:cted STSOs. TSA expects that by February 2014 all 4,400 STSOs will have attended this 

tmining. 

TSA will be building its training pOl1folio to support the expansion of courses that include 

similarl y tailored training for TSMs and other levels of TSA 's field leadership tearn, while also 

continuing 1[1 build a cmnprehcnsive tra ining portfolio for the STSO and LTSO l:adres. The 

specific project plans have not yet been de'vcloped tor these additional courses; however, project 

plans will be developed some lime in FY 2013. 

H.l!commendaCion 1#4: Develop and implement performance metric s to evaluate the supervision 

of checked baggage areas as part of supervisory performance plans and evaluations. These 

metries sllould include frequent direct observation of baggage screening activi ties. 

TSA conurs. TSA has a lready taken steps to implement th is recommendation. TSA chartered 

an Integrated Project Team to identify specific metrics that will allow TSA managers across the 

nation 10 mo re t!ffectively moni tor checked baggage sl:reening operations. STSOs will be 

www.oig.dhs.gov 27 OIG-12-128
 

 

 

OFFICE OF INSPECTOR GENERAL 

 Department of Homeland Security

6 

required to personally observe, collect, and repon specified data to senior management. Senior 

management will be better infonned about the need to follow up and evaluate the actions of a 

supervisor or a work unit, in response to an y nmed anomalies. TSA anti cipates that this data and 

the associated reporting requirements and metTies for checked baggage screening will be 

established at federalized airpOIts across the Nation by July 31, 20 13. 

www.oig.dhs.gov 28 OIG-12-128
 

 

 

OFFICE OF INSPECTOR GENERAL 

 Department of Homeland Security

Appendix C 

Representatives Mica and Chaffetz Request Letter 

~ngrrs'li 01 t1Jt ~l1lrtb §)tattll 

IiIwt,. gton, bt. 20515 

J:une21,2;(1l1 

OlurLCil K... Ed\ollwd8 

AcUng In:!Ip«:UM' Otoer.t..l 

U ,S. ~~f'I or (lml: ;K;Id 5ccuri1)' 

24$ MWI'O' I)rhoe, S W 

~ 41 0 ~&llsrop 2600 

W;uf)mgklO, DC 2OS2!J 

We, BIoo.e. wltb OW" w llcecuc:!l in ConCfCS8, cootinuc to be mo."" ;111 tbc T rJ.l1spal"W.lofL S«:\ul11 A dm.lnUllJUllono8 (rsA) 1l'lliUlagnne:nl and o~llht ori.... bl fl$l~ral 

K~f\CI' (I~ (lM. 1'he reccut pl"(l p(l~ f'T ~ ,.ra ~iaui6C1:f1 t TlllJnber or TS/ ... cmpll))'<le!I,. 

illCludina. membcmi of(be TSA's (I'A"JI koiiI;h:.UibijJ ~ 111 H~uJl,l lntc:m tioonl Airpor1 OINL) 

hl&hli&ht the confJlct dIm cxl w: .... b;m TSA lICU IW b(JI:lt the opo..'IUUJt' 8ftd ftIgl.IIiI r uribe avutioon. 

$C~n.i118 ~~. [\ is iatpe'n11Ii ... e 1M Pederlll .g nc.}' ~!olllms:ible fila ll101 inluin.i'l1B .VPU.oIll 

SC(:"';ty opcrntc:s in ... cff~ ~h'>e And dJ"lICil;nt !J1nOi~ , 

Wr! ~qut!5t } 't.JI.U I;tfllce conduct II tompliSl:! in~~jJYll: ion aorI tOOf'tWli!,ll n:-ncwo(wny n 

signilk:ant ponio!} ofdac TSA ge1CeIlcr .... 'Ori.:furee ot I'" T .. d~ ically failed iIl lhei.t 

pt.:tf~ .;.f critical ~1l0fl iteCtl~y k rtcntr18 n:~llilbtic$. Spt~ficlll )". 'I',l;! III"Cl 

imc~slcd in Ihc iolkl""'i!)l infunDllooo: 

A complete aD8 ~ or !.he failure ofTSA'. ovcr.dgltt and !iIiI~ I!l lotl or bsggage: aoo :l Jllk r scn..~ g cipi!tatJuat.. llI'I)1l!O.'Jl!I lind prOCctl'ures a tl lNL. 

A rcvit::W ofHNL TlW18pOrUi(ioo Sec.urily Office", (fSO) pcrlormlUll:C illdicarom.. pul 

evfiJUlldoM. and all perfomlilDoe re lato:J nl l")' llCliom, 

An eJe llmullil.iLm ur .... 1u::tlll::r d ie ~tiu l & .. d J"OeUrn:nl rr.:.inilJ8 n::qu~ 'I tor T'SOs!lf 

IIN'L ~~ C1l1'l'1:lJIlUld nt .".i th ll&1i(lRaJ lr.J.'inin& roqu rcm~IJI" 

www.oig.dhs.gov 29 OIG-12-128
 

 O

 

FFICE OF INSPECTOR GENERAL 

 Department of Homeland Security

Mr '!PI Cbldcs 'K . Edw.d, 

21. 2011 

.... -rA rnicw of the TSA 'I pmcCttKS to remo\'e non- or underpe:rforminc TS(Y. in Ct'nCllW, 

and ... ttNL iII~_ 

A ~view()rtht.: TSI\·. p l_Io.a:af'l' I"INL ik:n:x:nin¥opm1IltIDQII until pcn:nIllQlITSO 

tq)iKcmmu c.w\ be bircd _net _ned. IIOd if the TSA pllIm 10 dc9lo)' the NIIlic:lMl 

DepIoYft*lI F«ee.. an Mldit of 0,. 4OUI. 008$ or " .eh. dq:IloyllK.'tIIt. 

We RlCfUC31 )'Q\l~~. tbon;IIu&11 irJ~ipXiQn with. rqJCIrt fiDditlp.,d 

t\XUmrl'lCndMioat. 1ft. of)'OW Adchtiuo.llly ..... -e ~uo:fl. complete bricfinc b)' )'OU IUJd TOW aaIJ' rep dine 

)'OUr in'l"'C:I11ption.. I-.-e CQ:II..IIC1 Scaa McM n. with the ConurIiUClo 011 Tn.mpgrladon_ 

I.Crawu lOZ-lU-1!I048 IiOd )fivoJtclJ Komin*y "",bh tho ~ on ~&bt wxI 

OoYanmcal Rd'Otlll fit 202-225-501 . ..... i1h aft)' quH1lOa8. 

s· y, 

Jason Ow:trCIZ 

o..;~ 

incc on TIWJ!lfXln.-ioD bri:lomminec on NlitionnJ Sco.Irky. 

1t. ~ Homdalld tk.R"ftSIII: and Fon:l n 

O~ORII 

Commill _on~ a 

Govc:n llnCftl Rcfufnl 

www.oig.dhs.gov 3� OIG-12-128
 

 

 

 

 

 

 

 

 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security

Appendix D 

Review of Training 

The initial and recurrent training requirements for TSOs at HNL were current and 

consistent with TSA national training requirements. However, some TSOs did not meet 

all annual training requirements in FY 2010 and the first two quarters of FY 2011. The 

HNL Training Manager explained that some TSOs were not given enough time to 

complete required training, while others were not effectively using their time in the 

training labs. 

The Basic TSO Training Program requires all TSO candidates to complete a minimum of 

40 hours of classroom training and 60 hours of on-the-job training. HNL follows TSA’s 

New Hire Training Program, which requires new TSOs to complete seven Web-based 

training modules followed by 47 hours of classroom training and 65 hours of on-the-job 

training for checkpoint certification. New TSOs have to complete the Checked Baggage 

training section, which requires 16 hours of classroom training and 30 hours of on–thejob training, to receive certification for checked baggage. Of the 194 TSOs in our 

sample, 10 were new and subject to initial training during our scope-of-training review. 

All 10 TSOs completed the basic training requirements. 

All TSOs are required to take prescribed annual training courses to maintain proficiency 

with skills learned during basic training and to remain current with procedural changes, 

as well as new threat items. Recurrent training must be conducted in accordance with 

the National Training Plan. We selected the most relevant 21 courses to review during 

FY 2010 and the first two quarters of FY 2011. We randomly selected a statistically valid 

sample of 194 TSOs at HNL and those 43 TSOs who were involved in the security system 

failure4

 who are required to complete recurrent training requirements. The review of 

the statistical sample revealed the following completion rates: 

65 TSOs (33.5 percent) completed all 21 courses. 

91 TSOs (46.9 percent) completed 18 to 20 courses. 

19 TSOs (9.8 percent) completed 15 to 17 courses. 

13 TSOs (6.7 percent) completed 10 to 14 courses. 

Five TSOs (2.6 percent) completed one to nine courses. 

One TSO (0.5 percent) did not complete a training course. 

4

 Fifteen of the 43 TSOs were also included as part of the statistically valid sample of 194 TSOs. 

www.oig.dhs.gov 31 OIG-12-128
 

 

 

 

 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Our review of the 43 TSOs involved in the security system failure revealed the following 

results: 

22 TSOs (51.16 percent) completed all 21 courses.
 

15 TSOs (34.88 percent) completed 18 to 20 courses.
 

Six TSOs (13.95 percent) completed 15 to 17 courses.
 

www.oig.dhs.gov 32 OIG-12-128
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix E 

Review of Performance Indicators and Disciplinary Actions 

TSA has issued guidance for measuring performance and removing non- or 

underperforming TSOs. Each fiscal year, TSA’s Office of Human Capital develops 

performance criteria requiring TSOs to complete assessments to maintain certifications 

and screening functions, as well as measures for on-the-job performance. Additionally, 

TSA has issued guidance for progressive disciplinary actions that can be taken against an 

employee in response to unacceptable performance or conduct. We reviewed the 

performance indicators used to evaluate TSOs for the previous 3 fiscal years and the 

disciplinary actions issued at HNL. 

Performance Indicators and Evaluations 

PASS is a pay-for-performance management system serving many purposes for TSA 

employees, one of which is to measure and evaluate TSOs and TSMs. TSA measures 

TSOs and TSMs annually on items such as technical proficiencies, mandatory training, 

readiness for duty, and competencies (such as critical thinking, customer service, and 

decisionmaking). TSMs and Supervisory TSOs are responsible for rating, reviewing, and 

approving a TSO’s evaluation. 

Technical proficiency: Assesses TSOs’ ability to perform their screening function. It 

assesses their ability to master screening equipment and procedures. The TSO’s 

screening function and certification determine the assessments required for the fiscal 

year. For each required technical proficiency assessment, TSOs must satisfy the 

requirements and pass with three possible attempts. After each failed attempt, the TSO 

is removed from the screening function and receives training and coaching before 

another assessment is administered. The TSO is either retained and trained, or removed 

from employment. 

We reviewed the technical proficiencies for the 43 TSOs involved in the security system 

failure, as well as a statistically significant sample for FYs 2009–2011. Our review 

indicated that 100 percent of both the 43 TSOs and the sample passed the technical 

competency on ETD of checked baggage in FY 2009, FY 2010, and FY 2011. 

www.oig.dhs.gov 33 OIG-12-128
 

 

 

 

 

 

 

 

 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Mandatory training: Measures completion of required training items. This component 

was removed from performance evaluations in FY 2011 because TSA determined that it 

was not a performance component but merely a compliance with the National Training 

Plan. TSA put the responsibility on FSDs to monitor this requirement in a different 

format. In FY 2009, 99.74 percent of the TSOs in our statistical sample and 99.86 

percent of the TSOs involved in the security system failure completed the mandatory 

training. In FY 2010, 98.43 percent of the TSOs in our statistical sample and 99.45 

percent of the TSOs involved in the security system failure completed the mandatory 

training. 

Readiness for duty component: Measures a TSO’s and TSM’s dependability and 

professional presence. Specifically, this component measures items such as whether 

supervisors, managers, or rating officials have received corrective or progressive 

disciplinary action throughout the fiscal year for unscheduled leave, or uniform and 

appearance. 

Competencies: Measures an employee’s behavior and performance standards that are 

the most critical to job performance. For TSMs and Supervisory TSOs, it includes 

supervisory accountability and management proficiencies. Table 2 displays the 

competencies on which the TSOs and TSMs are rated. 

www.oig.dhs.gov 34 OIG-12-128
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Table 2: Competencies for Screening Workforce 

Competency TSO Lead Supervisory TSM 

TSO TSO 

Critical Thinking � � � �

Customer 

Service/Interpersonal 

Skills 

� � � �

Decisionmaking � � � �

Oral Communication � � � �

Coaching and 

Mentoring 

� � �

Conflict Management � �

Promoting a 

Performance-Based 

Culture at TSA 

� �

Readiness for Duty � �

Team Building �

Training and 

Development 

� �

Critical Incident and 

Management 

Reporting 

�

Program and Policy 

Compliance and 

Accountability 

�

SOP Compliance �

Staffing and 

Operational Needs 

�

Source: DHS-OIG. 

www.oig.dhs.gov 3� OIG-12-128
 

 

 

 

 

 

 

 

 

 

 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Competencies are evaluations that place employees into one of four different groups, 

with group 0 as the lowest and group 3 as the highest rating. Our review of the 

competencies indicated that a majority of the employees sampled were placed in the 

highest group. Interviews with TSMs and Supervisory TSOs at HNL showed that TSA 

does not have a consistent process for assigning these scores, and the score is subject to 

the perspective of the rating official. (See table 3.) 

Table 3: FY 2009 Through FY 2011 Competency Ratings for the 

Statistical Sample of 194 TSOs 

FY 2009 FY 2010 FY 2011 

Rating 0–2 3 0–2 3 0–2 3 

Critical Thinking N/A N/A 18% 82% 14% 86% 

Customer 

Service/Interpersonal Skills 21% 79% 16% 84% 15% 85% 

Decisionmaking 23% 77% 17% 83% 13% 87% 

Oral Communication 23% 77% 13% 87% 13% 87% 

Coaching and Mentoring N/A N/A 15% 85% 6% 94% 

Conflict Management 18% 82% 9% 91% 20% 80% 

Promoting a PerformanceBased Culture at TSA 27% 73% 9% 91% N/A N/A 

Readiness for Duty 0% 100% 9% 91% N/A N/A 

Team Building 0% 100% 0% 100% 7% 93% 

Training and Development 0% 100% 9% 91% N/A N/A 

Source: 

Note: Several competency factors changed between FY 2009 and FY 2011. 

Factors not assessed during a fiscal year are designated N/A, or not applicable. 

www.oig.dhs.gov 36 OIG-12-128
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

We selected a statistically valid sample of 194 TSOs and reviewed their group number 

on their performance evaluations for FYs 2009–2011. (See table 3.) In addition, we 

selected the 43 TSOs involved in the security system failure and reviewed their group 

numbers on their performance evaluations for the same fiscal years.5

 (See table 4.) 

Table 4: FY 2009 Through FY 2011 Competency Ratings for the 

43 TSOs Involved in the Security Failure 

FY 2009 FY 2010 FY 2011 

Rating 0–2 3 0–2 3 0–2 3 

Critical Thinking N/A N/A 2% 98% 0% 100% 

Customer Service/Interpersonal 

Skills 14% 86% 0% 100% 11% 89% 

Decisionmaking 12% 88% 2% 98% 0% 100% 

Oral Communication 17% 83% 0% 100% 0% 100% 

Coaching and Mentoring N/A N/A 0% 100% 0% 100% 

Conflict Management 0% 100% 0% 100% 0% 100% 

Promoting a Performance-Based 

Culture at TSA 0% 100% 0% 100% N/A N/A 

Readiness for Duty 0% 100% 0% 100% N/A N/A 

Team Building 0% 100% 0% 100% 0% 100% 

Training and Development 0% 100% 0% 100% N/A N/A 

Source� 

Note: Several competency factors changes between FY 2009 and FY 2011. Factors not 

assessed during a fiscal year or with no sampled employees rated are designated N/A, or not 

applicable. 

5

 Seventeen, 18, and 5 TSOs for FYs 2009 through 2011, respectively, were also included as part of the 

statistically valid sample of 194 TSOs. 

www.oig.dhs.gov 37 OIG-12-128
 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Disciplinary Actions

Several different actions—corrective, disciplinary, and adverse—can be taken to address 

unacceptable performance and conduct by a TSO. 

�	 Corrective actions: Administrative and nondisciplinary actions that inform an 

employee about unacceptable performance or conduct that should be corrected 

or improved. Examples of corrective actions include Letters of Counseling, 

Letters of Guidance and Direction, or Letters of Leave Restriction. 

�	 Disciplinary actions: Actions taken against an employee for failing to perform 

duties acceptably, interfering with others’ performance, or exhibiting conduct 

that adversely affects the agency’s ability to accomplish its mission. Examples of 

disciplinary actions include Letters of Reprimand and suspensions of 14 days or 

less. 

�	 Adverse actions: The most severe actions, including suspensions of more than 

14 days, involuntary demotion, or removal. 

All actions are initiated, completed, and filed by TSA airport management staff, including 

the Supervisory TSO, TSM, Assistant FSD, and FSD. The Supervisory TSO issues 

corrective actions and Letters of Reprimand, and can propose suspensions, while all 

other issuances must be at the TSM level or higher. The classification of a disciplinary 

and adverse action is determined by multiple factors. Factors include the nature and 

seriousness of the offense; whether the offense was intentional, technical, or 

inadvertent; employee’s job level; record of past disciplinary and adverse actions; length 

of service; performance on the job; and consistency of the penalty with other similarly 

imposed offenses. 

HNL issued 116 disciplinary and adverse actions between January 2009 and September 

2011. We reviewed disciplinary and adverse actions taken against TSOs selected in our 

random statistical sample of TSOs at HNL. 

Our review showed that TSA issued 16 actions from January 2009 through September 

2011. (See table 5.) 

www.oig.dhs.gov 38	 OIG-12-128
 
 

 

 

 

 

 

Table 5: Summary of Types of Disciplinary and Adverse Actions Taken 

Action Taken 2009 2011 Total 

Last Chance Agreement 

Letter of Reprimand 

Three-Day Suspension 

Seven-Day Suspension 

Fourteen-Day Suspension 

Total 

Source: d 

0 

3 

0 

1 

0 

4 

0 

2010 

1 

1 

1 

1 

4 

1 1 

4 8 

1 2 

2 4 

0 1 

8 16 

 

 

 

 

 

 

Table 6: Summary of Types of Disciplinary and Adverse Actions Taken 

Action Taken 2009 2010 2011 Total 

Last Chance Agreement 0 0 0 0 

Letter of Reprimand 5 3 0 8 

Three-Day Suspension 0 1 0 1 

Seven-Day Suspension 0 1 0 1 

Fourteen-Day Suspension 0 0 0 0 

Total 5 5 0 10

 Source: d 

 

 

 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

In addition to our statistically valid sample, we reviewed actions for those TSOs involved 

in the security system failure.6 Our review showed that TSO issued 10 actions from 

January 2009 through September 2011. (See table 6.) 

Disciplinary and adverse actions were issued to TSOs for failing to 

of an oversized item using ETD protocol, improperly escorting emergency 

personnel through a checkpoint, and multiple violations of leave restrictions. We also 

reviewed the corrective actions taken for a statistical sample of the TSOs employed at 

HNL for calendar years 2009 to September 2011 and those TSOs involved in the security 

system failure and not in the statistical sample. Instances for which a corrective action 

was issued included failing to mark checked bags as clear, allowing an airline porter to 

take unscreened bags, and leaving luggage in an EDS machine overnight. 

Fourteen of the 43 TSOs were also included as a part of the statistically valid sample of 194 TSOs. 

www.oig.dhs.gov 39 OIG-12-128

6 
 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix F 

Staff Involved in Security Failure 

No. Position Pay 

Band 

Salary 

Minimum 

Salary 

Maximum Personnel Action 

1 FSD SES 

Removal/Pending 

Appeal 

2 

Assistant FSD 

Screening K $89,338 $138,479 Retirement 

3 

Deputy Assistant 

FSD Screening J $74,732 $115,833 

Removal/Pending 

Appeal 

4 TSM I $61,256 $94,999 

Removal/Pending 

Appeal 

5 TSM H $50,273 $71,091 

Removal/Pending 

Appeal 

6 Supervisory TSO G $41,216 $63,860 Resignation 

7 Supervisory TSO G $41,216 $63,860 Removal 

8 Supervisory TSO G $41,216 $63,860 30-day suspension 

9 Supervisory TSO G $41,216 $63,860 21-day suspension 

10-14 Lead TSO F $35,214 $52,877 Removal 

15 Lead TSO F $35,214 $52,877 21-day suspension 

16 TSO E $30,685 $46,084 Retirement 

17-33 TSO E $30,685 $46,084 Removal 

34 TSO E $30,685 $46,084 Cleared 

35-42 TSO E $30,685 $46,084 30-day suspension 

43-44 TSO E $30,685 $46,084 21-day suspension 

45 TSO E $30,685 $46,084 14-day suspension 

46-48 TSO D $26,722 $40,084 Removal 

 

www.oig.dhs.gov 40 OIG-12-128
 

 

 

 

 

 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security

Appendix G 

HNL Airport Configuration 

Source: HNL W b 

The security system failure at HNL occurred in the screening area identified as Lobby 4, 

or the Overseas Terminal. The diagram below shows a closer look at the security set up 

of this area at the time of the security failure. 

Source:

www.oig.dhs.gov 41 OIG-12-128
 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix H 

Types of Checked Baggage Screening Searches 

Checked Baggage Screening SOP, Revision 4, April 2009 

 TSOs must sample and analyze the 

TSOs must inspect 

 TSOs must sample and analyze 

making no more than 

before analyzing the sampling media. 

In addition to the steps performed in the 

 TSOs must sample and analyze all items in the baggage that are the 

size of a or larger and conduct a physical search of any bag, box, 

or other container discovered inside the checked baggage that is the size of a 

or larger. 

Checked Baggage Screening SOP, Revision 5, January 2010 

 TSOs must perform a 

inspection of all items the size of a or larger. TSOs must also 

sample the as well as taking of the of 

or larger and the 
 

Checked Baggage Screening SOP, Revision 5, Change 2, March 2010 

 TSOs must perform a brief inspection of 

the bag and its contents. TSOs must also sample the of the bag as well 

as taking of the 

or larger and the 

www.oig.dhs.gov 42 OIG-12-128
 
 

 

 

 

 

 

 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security

Appendix I 

Major Contributors to This Report 

Patrick O’Malley, Director 

Christine Haynes, Audit Manager 

Kevin King, Auditor-In-Charge 

Gwendolyn Priestman, Program Analyst 

Enrique Leal, Auditor 

Elizabeth Clark, Program Analyst 

Maureen Duddy, Independent Referencer 

Kevin Dolloson, Communications Analyst 

www.oig.dhs.gov 43 OIG-12-128
 

 

 

 

 

 

 

 

 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security

Appendix J 

Report Distribution 

Department of Homeland Security 

Secretary 

Deputy Secretary 

Chief of Staff 

Deputy Chief of Staff 

General Counsel 

Executive Secretary 

Director, GAO/OIG Liaison Office 

Assistant Secretary for Office of Policy 

Assistant Secretary for Office of Public Affairs 

Assistant Secretary for Office of Legislative Affairs 

Acting Chief Privacy Officer 

Office of Management and Budget 

Chief, Homeland Security Branch 

DHS OIG Budget Examiner 

Transportation Security Administration 

Administrator 

Assistant Administrator, Office of Security Operations 

Transportation Security Administration Audit Liaison 

Congress 

Congressional Oversight and Appropriations Committees, as appropriate 

www.oig.dhs.gov 44 OIG-12-128
 

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