Report to Congressional Requesters

United States Government Accountability Office

GAO

October 2005 ATF

Thefts of Explosives 

from State and Local 

Government Storage 

Facilities Are Few but 

May Be 

Underreported 

GAO-06-92 
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

www.gao.gov/cgi-bin/getrpt?GAO-06-92.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Laurie Ekstrand 

at (202) 512-8777 or ekstrandl@gao.gov. 

Highlights of GAO-06-92, a report to 

congressional requesters 

October 2005

ATF

Thefts of Explosives from State and Local 

Government Storage Facilities Are Few 

but May Be Underreported 

Judging from available ATF data, there have been few thefts of explosives 

from state and local government storage facilities. From January 2002 to 

February 2005, ATF received only 9 reports of thefts or missing explosives 

from state and local facilities, compared with a total of 205 explosives thefts 

reported nationwide during this same period. During the course of our audit, 

we found evidence of 5 thefts from state and local government facilities, 1 of 

which did not appear in ATF’s national database on thefts and missing 

explosives. Thus, the actual number of thefts occurring at state and local 

storage facilities could be higher than that identified by ATF data. 

ATF has no authority to oversee or inspect all state and local government 

explosives storage facilities. State and local government agencies are not 

required to obtain a license from ATF to use and store explosives, and only 

licensees—such as private sector explosives storage facilities—are subject 

to mandatory oversight. As a result, ATF has no means to ensure that state 

and local government facilities are in compliance with federal regulations. 

While ATF does not collect nationwide information about state and local 

government explosives storage facilities, information about some of these 

facilities is collected—for example, when facility operators voluntarily 

request an ATF inspection. Since January 2002, ATF has conducted 77 

voluntary inspections at state and local storage facilities and found no 

systemic violations. By comparison, all licensed private sector facilities must 

submit a variety of information about their facility—including location and 

security measures in place— to ATF during the licensing process. ATF also 

collects information about these facilities during mandatory inspections. 

At the 18 state and local government storage facilities we visited, a variety of 

security measures were in place, including locked gates, fencing, patrols, 

and in some cases, electronic surveillance. All the facilities’ officials told 

GAO that they conducted routine inventories. But most were not required to 

be licensed or inspected by state or local regulatory agencies. We identified 

several instances of possible noncompliance with federal regulations, related

primarily to storage safety issues rather than security. 

Explosives Storage Facility in Pennsylvania 

Source: GAO.

More than 5.5 billion pounds of 

explosives are used each year in 

the United States by private sector 

companies and government 

entities. The Bureau of Alcohol, 

Tobacco, Firearms and Explosives 

(ATF) has authority to regulate 

explosives and to license privately 

owned explosives storage facilities. 

After the July 2004 theft of several 

hundred pounds of explosives from 

a state and local government 

storage facility, concerns arose 

about vulnerability to theft. 

GAO analyzed (1) the extent of 

explosives thefts from state and 

local government facilities, (2) 

ATF’s authority to regulate and 

oversee state and local government 

explosives storage facilities, (3) the 

information ATF collects about 

state and local government storage 

facilities, and (4) security oversight 

measures in place at selected state 

and local government storage 

facilities. 

What GAO Recommends

GAO recommends that the 

Attorney General direct the ATF 

Director to clarify explosives 

incident reporting regulations to 

ensure that all entities storing 

explosives, including state and 

local government agencies, 

understand their obligation to 

report all thefts or missing 

explosives. The Department of 

Justice agreed with GAO’s 

recommendation and indicated it 

would take steps to implement it. 
Page i GAO-06-92 Explosives Security 

Letter 1

Results in Brief 3 

Background 6 

Limited Data Indicate That Few Thefts May Have Occurred at State 

and Local Government Storage Facilities, but the Exact Number 

Is Uncertain 8 

ATF Authority to Oversee State and Local Government Explosives 

Storage Facilities Is Limited, as Is ATF’s Capacity to Absorb 

Additional Oversight Responsibilities 10 

ATF Does Not Collect Nationwide Information about State and 

Local Government Storage Facilities, but Does So for Licensed 

Private Sector Facilities 13 

Security Measures Varied at State and Local Explosives Storage 

Facilities We Visited 14 

Conclusions 26 

Recommendations for Executive Action 27 

Agency Comments and Our Evaluation 28 

Appendix I Scope and Methodology 29 

Tables 

Table 1: Overview of the State and Local Entities We Visited 16 

Table 2: Types of Physical Security in Place at the 18 Explosives 

Storage Facilities We Visited 20 

Table 3: Inventory and Oversight Activities at the 14 State and 

Local Entities Visited 24 

Table 4: State and Local Entities Visited 30 

Figures 

Figure 1: Type 1 (Permanent Structure) Explosives Storage 

Magazines in Texas and Colorado 17 

Figure 2: Type 2 (Mobile) Explosives Storage Magazines in 

Pennsylvania and Tennessee 18 

Figure 3: Type 3 (Portable Day-Box) Explosives Storage Magazine 

in Pennsylvania 19 

Figure 4: Pennsylvania Storage Facility with Interior Barrier 

Surrounding Type 2 Storage Magazines 21 

Contents 
Page ii GAO-06-92 Explosives Security 

Abbreviations 

ATF Bureau of Alcohol, Tobacco, Firearms and Explosives 

DOJ Department of Justice 

FBI Federal Bureau of Investigation 

OIG Office of the Inspector General 

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

United States. It may be reproduced and distributed in its entirety without further 

permission from GAO. However, because this work may contain copyrighted images or 

other material, permission from the copyright holder may be necessary if you wish to 

reproduce this material separately. 
Page 1 GAO-06-92 Explosives Security 

October 3, 2005 

The Honorable Christopher Shays 

Chairman, Subcommittee on National Security, 

 Emerging Threats, and International Relations 

Committee on Government Reform 

House of Representatives 

The Honorable Tom Lantos 

House of Representatives 

More than 5.5 billion pounds of explosives are used each year in the 

United States. These explosives are used by both public sector entities 

(such as state and local government agencies) and private sector 

companies for a variety of purposes—including mining, construction, 

avalanche control, and law enforcement.1

 Under current federal explosives 

laws and regulations, the Bureau of Alcohol, Tobacco, Firearms and 

Explosives (ATF) is responsible for licensing and regulating explosives 

manufacturers, importers, dealers, and users. ATF’s authority to regulate 

explosives stems originally from the Organized Crime Control Act of 1970 

and was expanded further by enactment of the Safe Explosives Act in 

2002.2

 It is primarily through its licensing authority that ATF oversees and 

inspects privately owned explosives facilities to ensure they comply with 

explosives storage laws and regulations. With regard to governmentowned explosives storage facilities, state and local agencies are also 

subject to federal explosives storage laws and regulations, but exempt 

from the ATF licensing requirements.3

In July 2004, several hundred pounds of explosives were stolen from law 

enforcement storage magazines at a city/county storage facility in 

 1

 Law enforcement bomb squads, for example, may store explosives for a number of uses—

including destroying recovered explosives, dismantling explosive devices, and holding 

explosive materials for evidence. 

2

 Specifically, Title XI of Public Law 91-452, 84 Stat. 922, 952 (1970); and Subtitle C of Title 

XI of Public Law 107-296, 116 Stat. 2135, 2280 (2002), respectively. 

3

 An approved storage facility is defined as a place where explosive materials are stored, 

consisting of one or more approved storage magazines. A storage magazine is defined as 

any building or structure, other than an explosives manufacturing building, used for 

storage of explosive materials. 

United States Government Accountability Office

Washington, DC 20548 
Page 2 GAO-06-92 Explosives Security 

California. The thieves were subsequently arrested and the explosives 

were recovered. Out of concern that state and local government 

explosives storage facilities could be vulnerable to theft, you asked us to 

provide information regarding the security oversight of these facilities. For 

this report, we focused on the following questions: 

1. What is the extent of explosives thefts from state and local 

government facilities and how does this compare with the total 

number of explosives thefts reported nationwide? 

2. What authority does ATF have to regulate and oversee state and 

local government explosives storage facilities and how does this 

compare with its authority over private sector storage facilities? 

3. What information does ATF collect regarding the locations and 

types and amounts of explosives stored at state and local 

government explosives storage facilities and how does this 

compare with information collected about private sector storage 

facilities? 

4. What security oversight measures are in place at selected state and 

local government storage facilities to ensure the safe and secure 

storage of explosives? 

To address these questions, we obtained information from U.S. 

government agencies, law enforcement associations, industry groups, and 

other experts on explosives. More specifically, to obtain the perspectives 

of U.S. government agencies on their efforts to regulate and oversee state 

and local government explosives storage facilities, and to obtain 

information on the numbers of explosives thefts and law enforcement 

bomb squads, we contacted officials from the Department of Justice 

(DOJ), ATF, and the Federal Bureau of Investigation (FBI). To obtain 

other public sector and private sector perspectives on the security 

oversight of explosives storage facilities, we contacted associations 

representing state and local law enforcement agencies and the explosives 

industry. To determine what selected states and localities are doing to 

provide oversight of explosives storage in state and local government 

sector facilities, we met with officials at 14 state and local government 

entities (13 law enforcement bomb squads and one public university) in 

four states—Colorado, Pennsylvania, Tennessee, and Texas—and 

observed their explosives storage facilities. We selected these four states 

to obtain a geographic spread (west, northeast, southeast, and southwest) 

across the country, based on (1) the number of explosives licensees and 
Page 3 GAO-06-92 Explosives Security 

reported explosives thefts, (2) the number of law enforcement bomb 

squads, and (3) the location of universities with mining programs.4

 Our 

criteria for identifying the type of security oversight measures in place 

included existing federal explosives storage laws and regulations and 

security guidelines issued by the explosives industry. Because we selected 

and visited a limited nonprobability sample of 14 state and local entities in 

the four states, the information discussed in this report cannot be 

generalized to all state and local government agencies that store 

explosives. Additional detail on our scope and methodology is provided in 

appendix I. 

We conducted our work from February through August 2005 in 

accordance with generally accepted government auditing standards. 

Judging from available ATF data, there have been few thefts of explosives 

from state and local government storage facilities. However, reports of 

thefts could be understated by an unknown amount. During the 3-year 

period from January 2002 to February 2005, ATF received only 9 reports of 

thefts or missing explosives from state and local government storage 

facilities. By comparison, during this same time period there were a total 

of 205 explosives thefts reported from all sources nationwide. There are 

two federal reporting requirements relating to the theft of explosives—one 

is specific to explosives licensees (and permittees) and the other generally 

applies to “any person who has knowledge of the theft or loss of any 

explosive materials from his stock.” While ATF has interpreted this second 

reporting requirement as applying to nonlicensed state and local 

government explosives storage facilities, ATF officials acknowledged that 

state and local government entities may be unclear as to whether they are 

covered under this requirement. Indeed, this lack of clarity issue may have 

contributed to our findings: During our audit, we found evidence of five 

thefts from state and local government facilities, one of which did not 

appear in ATF’s national database on thefts and missing explosives. 

Because of this, the total number of thefts occurring at state and local 

government storage facilities could actually be more than the number 

identified by ATF data. 

 4

 We are not disclosing the names or other identifying information relating to the individual 

state and local entities we visited to ensure that security-related information is not 

unintentionally disclosed. 

Results in Brief 
Page 4 GAO-06-92 Explosives Security 

Although federal storage requirements are applicable to state and local 

government explosives storage facilities, ATF does not have oversight 

authority with respect to these facilities. With respect to private sector 

facilities, ATF oversight—including the ability to conduct regulatory 

inspections—is linked to the licensing of facilities. Private sector 

businesses and organizations that import, manufacture, or deal in 

explosives are required to obtain a federal license. As a requirement of the 

licensing process, private sector licensees are generally subject to 

mandatory ATF oversight inspections of their explosives storage facilities. 

State and local government agencies that use and store explosives are not 

required under federal explosives law to obtain a license from ATF. In 

addition, ATF does not have specific statutory authority to conduct 

regulatory inspections at state and local explosives storage facilities. State 

and local government storage facilities are generally not inspected by ATF, 

unless the facility operator voluntarily requests such an inspection or 

shares its storage magazine with ATF. As a result, ATF has no means to 

ensure that all state and local government facilities nationwide are in 

compliance with federal storage regulations. 

ATF does not collect nationwide information on the number and location 

of state and local government storage facilities or the types and amounts 

of explosives that are being stored in these facilities. State and local 

government agencies are exempt from obtaining a federal explosives 

license, and they are not subject to ATF oversight authority. As a result, 

ATF has no real way of knowing the precise number of these facilities or 

the extent to which their explosives storage facilities are secure from 

theft. For a limited number of state and local government facilities—those 

that request a voluntary inspection or where ATF shares a state and local 

magazine—ATF conducts inspections that allow it to collect information 

about such things as the location and characteristics of these storage 

facilities. However, because ATF does not have authority to conduct 

mandatory inspections of all state and local government entities, ATF has 

no means to collect this type of information nationwide. Although ATF 

cannot gather information about state and local government entities, it is 

able to collect a variety of information about private sector explosives 

licensees, who operate roughly 7,500 storage facilities and nearly 23,000 

permanent or mobile storage magazines in the United States. Information 

about these storage facilities and the explosives being stored is required to 

be submitted to ATF during the licensing application process. Additional 

information is collected during the course of mandatory ATF inspections 

of licensees. During our audit, we identified various types of state and 

local government agencies that use and store explosives—including law 

enforcement bomb squads, public universities, and departments of 
Page 5 GAO-06-92 Explosives Security 

transportation. However, we did not gather sufficient information about 

these entities to reliably estimate the total number of state and local 

government storage facilities and magazines nationwide. 

At the 14 state and local entities we visited, we observed a variety of 

security measures in place at their 18 storage facilities. Regarding physical 

security, most storage facilities had some kind of locked gate to prevent 

vehicle access, and several had fencing surrounding their storage facilities 

or storage magazines. At each of these facilities, officials told us they 

visually inspected or patrolled the facility on a regular basis. Four storage 

facilities also had electronic security systems in place—either monitored 

alarms or video surveillance—although one of these was out of service at 

the time of our visit. Officials at several other entities said they were 

actively planning to implement some form of electronic security or were in 

the process of installing a security system in the near future at their 

storage facilities. These types of security measures—fences, vehicle 

barriers and electronic monitoring devices—all exceed the requirements 

of federal explosives regulations. Regarding oversight activities, officials at 

all the entities we visited told us they conducted routine inventories of 

their storage facilities. Most facilities were not required to be licensed or 

inspected by state or local regulatory agencies, although several officials 

said they had previously had their storage facilities inspected by ATF. Two 

of the 14 entities we visited had previously reported a loss or experienced 

a theft of explosives, but only one of these incidents appeared in ATF’s 

nationwide theft database. 

To allow ATF to better monitor and respond to incidents of missing or 

stolen explosives, we are recommending that the Attorney General direct 

the ATF Director to clarify the explosives incident reporting regulations to 

ensure that all persons and entities who store explosives, including state 

and local government agencies, understand their obligation to report all 

thefts or missing explosives to ATF within 24 hours of an occurrence. 

We provided a draft of this report to DOJ for its review and comment. DOJ 

agreed with our recommendation and also provided technical comments, 

which we have incorporated into the report, as appropriate. 
Page 6 GAO-06-92 Explosives Security 

ATF is the chief enforcer of explosives laws and regulations in the United 

States and is responsible for licensing and regulating explosives 

manufacturers, importers, dealers, and users.5

 ATF is also responsible for 

regulating most, but not all, explosives storage facilities. ATF’s regulatory 

authority over explosives stems from the Organized Crime Control Act of 

1970.6

 This statute imposed controls over the importation, manufacture, 

distribution, and storage of explosives, and was the basis for giving ATF 

enforcement responsibilities for these controls.7

 The Safe Explosives Act 

expanded ATF’s authority to generally require licenses for persons who 

purchase or receive explosives and background checks on licensees and 

their employees who handle explosives.8

Under federal explosives regulations, a license is required for persons who 

manufacture, import, or deal in explosives and, with some exceptions, for 

persons who intend to acquire explosives for use. No license is required 

solely to operate an explosives storage facility. However, all persons who 

store explosive materials (including state and local agencies) must 

conform with applicable ATF storage regulations, irrespective of whether 

they are required to obtain an explosives license for other purposes. State 

and local agencies are not required to obtain an explosives license to use 

and store explosives. Similarly, federal government agencies, the U.S. 

military, and other federally owned or operated establishments are exempt 

from compliance with both the licensing and the storage regulations. 

According to ATF data, as of February 2005 there were 12,028 federal 

explosives licensees in the United States.9

 Roughly 7,500 of these had some 

kind of explosives storage facility, consisting of 22,791 permanent or 

mobile storage magazines. 

 5

 Licenses are issued to persons who manufacture, import, or sell explosives, while permits 

are issued to persons who intend to acquire and use explosives. Throughout the remainder 

of this report, references to explosives licenses, licensees, or ATF’s licensing authority 

refer to both explosives licenses and permits. 

6

 Pub. L. No. 91-452, Title XI, 84 Stat. 922, 952 (1970). The explosives regulatory functions of 

ATF are found at 27 C.F.R. Part 555. 

7

 Pursuant to the Homeland Security Act of 2002 (Pub. L. No. 107-296, 116 Stat. 2135, 2280), 

ATF’s existing enforcement responsibilities, including its authority over explosives, were 

transferred from the Treasury Department to the new Bureau of Alcohol, Tobacco, 

Firearms and Explosives, within the Justice Department. All ATF regulations issued prior 

to that time remained in effect. 

8

 Subtitle C of Title XI of the Homeland Security Act of 2002. 

9

 Including licensees in the District of Columbia, Guam, Puerto Rico, and the Virgin Islands. 

Background 
Page 7 GAO-06-92 Explosives Security 

ATF storage regulations include requirements relating to the safety and 

security of explosives storage magazines—that is, any building or 

structure (other than an explosives manufacturing building) used for 

storage of explosive materials. Regarding safety, the storage regulations 

include requirements related to location, construction, capacity, 

housekeeping, interior lighting, and magazine repairs, as well as a 

requirement that the local fire safety authority be notified of the location 

of each storage magazine. Regarding security, the ATF storage regulations 

include the following requirements: 

• Explosives handling. All explosive materials10 must be kept in locked 

magazines unless they are in the process of manufacture, being 

physically handled in the operating process of a licensee or user, being 

used, or being transported to a place of storage or use. Explosives are 

not to be left unattended when in portable storage magazines. 

• Magazine construction. Storage magazines must be theft-resistant and 

must meet specific requirements dealing with such things as mobility, 

exterior construction, door hinges and hasps, and locks. 

• Magazine inspection. Storage magazines must be inspected at least 

every 7 days. This inspection need not be an inventory, but it must be 

sufficient to determine if there has been an unauthorized entry or 

attempted entry into the magazines, or unauthorized removal of the 

magazine contents. 

• Magazine inventory. Within the magazine, containers of explosive 

materials are to be stored so that marks are visible. Stocks of explosive 

materials are to be stored so they can be easily counted and checked. 

Notwithstanding the security requirements described above, ATF storage 

regulations do not require explosives storage facilities to have any of the 

following physical security features—fences, restricted property access, 

exterior lighting, alarm systems, or electronic surveillance. Also, while 

ATF licensing regulations require explosives licensees to conduct a 

physical inventory at least annually, there is no similar inventory 

requirement in the storage regulations applicable to other persons who 

store explosives. 

 10 As defined in the federal explosives law and regulations at 18 U.S.C. § 841 and 27 C.F.R. § 

555.11. 
Page 8 GAO-06-92 Explosives Security 

According to ATF data, the number of reported state and local government 

thefts is relatively small when compared with the total number of thefts 

that have occurred nationwide. For example, during a recent 3-year period 

(January 2002—February 2005), 9 thefts involving state and local 

government storage facilities were reported. Of these, 5 involved state and 

local law enforcement agencies (1 was later determined to be the possible 

result of training explosives that had been mistakenly discarded), 3 others 

involved state government entities (all universities), and the remaining 

incident took place at a county highway department. Two of the 9 

incidents occurred in California (including last year’s theft that was 

mentioned previously), and no other state reported more than one 

incident. By comparison, during this same period, ATF received reports of 

205 explosives thefts nationwide from all sources. Three states—

California, Texas, and Pennsylvania—accounted for about one-quarter 

(53) of the total reported thefts nationwide. According to ATF officials, 

this may be due to the larger numbers of explosives licensees and storage 

magazines located in these three states. 

The amounts of explosives reported stolen or missing from state and local 

government facilities in each reported incident of theft are also relatively 

small when compared with the total amounts of stolen and missing 

explosives nationwide. For example, during a recent 10-month period for 

which data were available (March 2003 through December 2003), there 

were a total of 76 theft incidents nationwide reported to ATF, amounting 

to a loss of about 3,600 pounds of high explosives, 3,100 pounds of blasting 

agents, 1,400 detonators, and 2,400 feet of detonating cord and safety fuse. 

By comparison, over an entire 10-year period (January 1995—December 

2004), ATF received only 14 reports of theft from state and local law 

enforcement storage magazines. In 10 of these incidents, less than 50 

pounds of explosives was reported stolen or missing; while in 3 of the 

incidents, more than 50 pounds was stolen or missing.11 In 6 of these 14 

cases, ATF data indicate that most or all of the explosives were recovered; 

in the other 8 cases, none of the explosives have been recovered. 

While the ATF theft data indicate that thefts from state and local facilities 

make up only a small part of the overall thefts nationwide, these reports 

may be understated by an unknown amount. There are two federal 

reporting requirements relating to the theft of explosives. One is specific 

 11 For the remaining incident, no details were available on the quantity of explosives 

involved. 

Limited Data Indicate 

That Few Thefts May 

Have Occurred at 

State and Local 

Government Storage 

Facilities, but the 

Exact Number Is 

Uncertain 
Page 9 GAO-06-92 Explosives Security 

to all federal explosives licensees (and permittees) and requires any 

licensee to report any theft or loss of explosives to ATF within 24 hours of 

discovery. The second reporting requirement generally requires any other 

“person” who has knowledge of the theft or loss of any explosive materials 

from his stock to report to ATF within 24 hours. Although the term 

“person” as defined in law and regulation does not specifically include 

state and local government agencies,12 ATF has historically interpreted this 

requirement as applying to nonlicensed state and local government 

explosives storage facilities. With respect to the second reporting 

requirement, according to ATF, the legislative history of the Organized 

Crime Control Act of 1970 indicates that Congress believed visibility over 

all incidents [emphasis added] of stolen explosives was necessary to 

effectively enforce any federal explosives regulatory statute—primarily 

because of the special problems presented by stolen explosive materials 

and the persons possessing them. 

While ATF has interpreted the theft reporting requirement as applying to 

state and local government explosives storage facilities, ATF officials 

acknowledged that state and local government entities could be unsure as 

to their coverage under the theft reporting requirements. As a result, some 

state and local government entities may not know they are required to 

report such incidents to ATF, and this lack of information could impair 

ATF’s ability to monitor these incidents and take appropriate investigative 

action. Indeed, during our site visits and other state and local contacts, we 

identified five state and local government entities that had previously 

experienced an incident of theft or reported missing explosives—two 

involving local law enforcement agencies, two involving state universities, 

and one involving a state department of transportation.13 However, one of 

these five incidents did not appear in ATF’s nationwide database of 

reported thefts and missing explosives. Based on these findings, the actual 

number of thefts occurring at state and local government storage facilities 

nationwide could be more than the number identified by ATF data. 

 12 The term “person” is defined in statute and regulation as “any individual, corporation, 

company, association, firm, partnership, society, or joint stock company” (see 18 U.S.C. § 

841(a); and 27 C.F.R. § 555.11). 

13 Two of these five incidents occurred at locations we visited; three occurred at other 

locations we identified during the course of our audit work. 
Page 10 GAO-06-92 Explosives Security 

With certain exceptions (such as for federal agencies), federal explosives 

law requires all persons who store explosives to conform to applicable 

regulations. However, there is no ATF oversight mechanism in place to 

ensure that state and local government facilities have complied with the 

regulations. With respect to private sector entities, ATF’s authority to 

oversee explosives storage facilities is primarily a function of its licensing 

process. However, the licensing requirements described in the law and 

regulations above do not apply to the transportation, shipment, receipt, or 

importation of explosive materials to any state or its political subdivision 

(such as a city or county). That is, government entities, such as state and 

local law enforcement agencies, are not required to obtain a federal 

license to use and store explosives. In addition, ATF does not have 

specific statutory authority to conduct regulatory inspections at state and 

local explosives storage facilities. As a result, these facilities are not 

subject to mandatory oversight under ATF’s licensing authority or any 

ATF regulatory inspection authority apart from the licensing process. 

ATF may inspect state and local government storage facilities under 

certain circumstances—for example, if the operator of the facility 

voluntarily requests ATF to conduct an inspection. Since January 2002, 

ATF has conducted 77 voluntary inspections at state and local storage 

facilities—34 inspections at facilities that ATF shares with state and local 

agencies and 43 inspections at other state and local facilities.14 These 

inspections basically involve checking for compliance with federal storage 

regulations, including verifying proper construction of the storage 

magazine and verifying that the amount of explosives stored is consistent 

with the approved table of distances.15 In addition to conducting voluntary 

inspections, ATF also conducts inspections of state and local explosives 

storage magazines that are shared by ATF and a state or local agency. ATF 

currently shares space in 52 storage magazines, including 33 that are 

owned or leased by state and local agencies. Shared magazines are subject 

to mandatory inspections by ATF, and the inspection procedures are 

basically the same as those described above for voluntary inspections. 

According to ATF officials, no significant or systemic safety or security 

problems have been found during inspections of state and local storage 

 14 As discussed later in this report, the total number of state and local government storage 

facilities nationwide is currently unknown. 

15 As published in the federal storage regulations, the table of distances lists the minimum 

acceptable distances separating explosives magazines from inhabited buildings, passenger 

railroads, public highways, and other explosives magazines. 

ATF Authority to 

Oversee State and 

Local Government 

Explosives Storage 

Facilities Is Limited, 

as Is ATF’s Capacity 

to Absorb Additional 

Oversight 

Responsibilities 
Page 11 GAO-06-92 Explosives Security 

magazines. However, regarding those state and local government facilities 

that ATF does not inspect, ATF officials acknowledged they had no way of 

knowing the extent to which these facilities are complying with federal 

storage regulations. 

By comparison with state and local government entities, private sector 

licensees are subject to mandatory ATF oversight and inspection. Under 

provisions of the Safe Explosives Act, ATF is generally required to 

physically inspect a license applicant’s storage facility prior to issuing a 

federal explosives license—which effectively means at least one 

inspection every 3 years. This inspection is intended to verify that the 

applicant’s storage facility complies with federal regulations regarding 

safety and security, and the inspection requirement applies to original 

license applications, as well as renewals (with certain exceptions).16 In 

addition, the regulations allow ATF to inspect licensees at any time during 

business hours, for the purpose of inspecting or examining any records or 

documents required to be maintained and any explosive materials kept or 

stored at the premises. 

ATF officials stated that if the agency were to be required to conduct 

mandatory inspections of state and local government storage facilities, 

they would likely need additional resources to conduct these inspections 

because they are already challenged to keep up with inspections that are 

mandated as part of the explosives licensing requirements. One factor that 

affects ATF’s ability to meet inspection goals is that inspectors have to 

conduct inspections of licensed firearms dealers, manufacturers, and 

importers, as well as explosives licensees. As noted above, ATF must 

physically inspect explosives licensees at least once every 3 years—or 

about one-third (4,000) of the roughly 12,000 licensees each year. 

According to ATF officials, because license applications and renewals are 

not evenly distributed over this 3-year cycle, some years there may 

actually be more or less than 4,000 inspections per year. ATF currently has 

723 field inspectors, 620 of whom regularly conduct explosives and 

firearms inspections (the others are in supervisory or administrative 

positions). About 20 percent of the inspection time is spent on explosives 

inspections; the remainder is spent on firearms. 

 16 An exception is made for “limited” licenses which are good for 1 year and allow a limited 

number of explosives purchases. For new applicants (and up to two renewals), ATF may 

verify the safety and security of the applicant’s storage facility by means other than an 

inspection. 
Page 12 GAO-06-92 Explosives Security 

In July 2004, DOJ’s Office of the Inspector General (OIG) reported that 

ATF’s inspections program was being affected by staffing shortages. The 

OIG noted that in response to passage of the Safe Explosives Act, ATF had 

to divert resources from firearms inspections to conduct explosives 

inspections required under the act. The OIG report further stated that ATF 

had calculated (and reported to Congress) that it needed almost 1,800 

inspectors—including 540 just for explosives inspections—to manage its 

existing inspection workload at that time.17 To help ATF carry out its 

explosives responsibilities, the conferees on the DOJ appropriations act 

for fiscal year 2005 directed funding increases in fiscal year 2005 for the 

hiring of an additional 31 explosives inspectors, for purposes of explosives 

investigations and regulatory compliance.18 In addition, the House 

Committee on Appropriations has recommended additional funding in 

ATF’s fiscal year 2006 appropriation, for the hiring of another 50 

explosives inspectors.19 Despite these increases, giving ATF additional 

responsibility to oversee state and local government storage facilities 

could further tax the agency’s inspection resources. According to ATF 

officials, because of the legislative mandate to physically inspect 

explosives licensees, the effect of additional state and local government 

explosives responsibilities (without similar increases in inspector 

resources) could be to reduce the number of firearms inspections that 

ATF could conduct. 

 17 The OIG disputed these figures, but still estimated ATF needed about 800 inspectors just 

for firearms inspections. This is more than the total number of firearms and explosives 

inspectors that are currently on board. 

18 H. R. Conf. Rep. No. 108-792, at 733 (2004). 

19 H. R. Rep. No. 109-118, at 34 (2005). 
Page 13 GAO-06-92 Explosives Security 

According to ATF officials, ATF does not collect nationwide information 

on the number and location of state and local government explosives 

storage facilities, nor does the agency know the types and amounts of 

explosives being stored in these facilities. With respect to private sector 

licensees, ATF collects descriptive information concerning explosive 

storage facilities as part of the licensing process. However, state and local 

government explosive storage facilities are not required to obtain a license 

from ATF, and ATF does not have specific statutory authority to conduct 

regulatory inspections of such facilities. As a result, no systematic 

information about these facilities is collected. For those state and local 

government facilities that ATF does inspect—either voluntary inspections 

of state and local magazines or mandatory inspections of shared 

magazines—some information is collected by ATF. During these 

inspections, ATF collects information about the location of the storage 

magazines, the types and amounts of explosives stored, and whether the 

magazines are in compliance with federal storage regulations. According 

to ATF officials, the information obtained from these inspections—along 

with the results from inspections of licensees—are maintained in ATF’s NSpect nationwide inspection database. While mandatory annual 

inspections are required by ATF at each of the 33 state and local 

magazines where ATF shares storage space, there have been only 77 

voluntary inspections of state and local storage magazines since January 

2002. ATF also has some ability to monitor state and local storage facilities 

at locations where ATF maintains its own storage magazine. ATF 

headquarters and field offices currently have 118 storage magazines 

colocated at facilities with state and local storage magazines. For these 

facilities, ATF collects information about the location of the facility and 

the inspection status of any state and local magazines on site.20 Of the 77 

voluntary inspections discussed above, 34 were at these colocated 

facilities. 

By comparison, ATF collects a variety of information about private sector 

explosives storage facilities, primarily under its authority to issue 

explosives licenses. For example, ATF license application forms require 

applicants for an explosives license to submit information about their 

storage capabilities. Specific information applicants are required to submit 

to ATF includes the type of storage magazine, the location of the 

magazine, the type of security in place, the capacity of the magazine, and 

the class of explosives that will be stored. ATF also collects information 

 20 Such as whether the state and local magazines have been voluntarily inspected by ATF. 

ATF Does Not Collect 

Nationwide 

Information about 

State and Local 

Government Storage 

Facilities, but Does So 

for Licensed Private 

Sector Facilities 
Page 14 GAO-06-92 Explosives Security 

about private sector storage facilities during mandatory licensee 

inspections. As noted previously, prior to issuing or renewing an 

explosives license, ATF must generally verify by on-site inspection that the 

applicant has a storage facility that meets the standards of public safety 

and security against theft as prescribed in the regulations. Thereafter, ATF 

may also inspect a licensee at any time during business hours—including 

inspection of storage magazines, examination of explosives inventory and 

sales records, and verification of compliance with ATF administrative 

rules. Because state and local government storage facilities are exempt 

from the licensing process described above, they are not required to 

submit licensing-related information about their storage facility to ATF 

and they are not subject to licensing-related mandatory ATF inspections. 

In addition, ATF does not have specific statutory authority to perform 

regulatory oversight inspections of such facilities apart from the licensing 

process. As a result, ATF is unable to collect complete nationwide 

information about where these facilities are or the types and amount of 

explosives they store. 

During the course of our audit work, we compiled data on state and local 

law enforcement bomb squads that would be likely to use and store 

explosives. At the 13 state and local law enforcement bomb squads we 

visited, we identified 16 storage facilities and 30 storage magazines. At 

these locations, the number of storage facilities ranged from 1 to 2, and the 

number of storage magazines ranged from 1 to 4. According to FBI data, 

there are currently 452 state and local law enforcement bomb squads 

nationwide. The total number of state and local government storage 

facilities and magazines nationwide, however, encompasses other entities 

in addition to law enforcement bomb squads—including other law 

enforcement agencies, public universities, and departments of 

transportation. The precise number of storage facilities and magazines at 

these locations is currently unknown. And because of the limited nature of 

our fieldwork, we cannot generalize about the extent of security and 

oversight these entities may have at their own explosives storage facilities. 

We found that security oversight measures varied at the 14 selected state 

and local government entities we visited. These 14 entities maintained a 

total of 18 storage facilities. With regard to physical security, 13 of the 18 

storage facilities restricted vehicle access to the storage area. Six of the 18 

storage facilities also had a barrier immediately surrounding the storage 

containers preventing human access. Official personnel at all 18 facilities 

said they patrolled or inspected the storage facility on a regular basis. 

Regarding electronic security, 4 of the 18 facilities had either an alarm or 

Security Measures 

Varied at State and 

Local Explosives 

Storage Facilities We 

Visited 
Page 15 GAO-06-92 Explosives Security 

video monitoring system in place. Inventory and other oversight activities 

at all 14 of the state and local entities included regular, periodic 

inventories of the contents of their explosives storage facilities. In 

addition, a federal, state, or local government authority had performed 

inspections for 9 of the 14 entities. State government agencies in Colorado 

and Pennsylvania required 5 state and local entities we visited in these 

states to obtain licenses to operate their explosives storage facilities. 

However, 2 of these 5 entities did not have the required licenses in place at 

the time of our visit. Two of the 14 entities had experienced prior thefts or 

losses from their storage facilities, and we observed storage practices at 

four facilities that may not be in compliance with federal regulations. 

The following sections describe our observations of the explosives storage 

magazines and types of security measures in place at the 18 state and local 

storage facilities we visited. Our criteria for identifying the type of security 

measures in place included existing federal explosives storage laws and 

regulations (27 C.F.R., Part 555, Subpart K) and security guidelines issued 

by the explosives industry (the Institute of Makers of Explosives). Most of 

these security measures are not currently required under federal storage 

regulations (perimeter fencing, for example). However, we are presenting 

this information in order to demonstrate the wide range of security 

measures actually in place at the time of our visits. 

As shown in table 1, the 14 state and local government entities we visited 

included 11 city or county bomb squads (including police departments and 

sheriffs’ offices), 2 state bomb squads, and one public university. Four of 

the 14 state and local entities had two separate storage areas 

encompassing a total of 18 explosives storage facilities among the 14 

entities. As further shown in table 1, 17 of these explosives storage 

facilities were located on state, city, county, or police property. These 

included 3 that were located on state property (such as state law 

enforcement or state university), 7 that were located at police training 

facilities, and 7 that were located on city or county government-owned 

property (such as correctional or water facilities). For example, one local 

entity we visited in Texas had a storage facility located on the grounds of a 

city-owned nature preserve. 

Explosives Storage 

Facilities Varied with 

Regard to Users and Size 
Page 16 GAO-06-92 Explosives Security 

Table 1: Overview of the State and Local Entities We Visited 

 Number Examples 

State and local entities 14 

Agency type 

• State bomb squad 2 State police and highway patrol 

• City/county bomb 

squad 11

 Police departments and sheriffs’ offices 

• Public university 1 School with mining engineering curriculum 

Storage facility 

locations 18

 

Property type 

• Police training 7 Academy or other training facility 

• State 3 University, state law enforcement 

• City/county 7 Correctional facility, water treatment, nature park 

• Airport 1 Airport grounds 

Storage magazines 34 

Magazine types 

• Type 1 (permanent) 10 7 aboveground, 3 underground 

• Type 2 (mobile) 22 19 box-type, 3 trailer-type 

• Type 3 (temporary) 2 2 day-boxes used for permanent storage 

Source: GAO observation, comments by state and local government officials, and ATF regulations. 

Also, 11 of the 18 explosives storage facilities we visited contained 

multiple magazines for the storage of explosives. As a result, the 18 

facilities housed a total of 34 magazines divided into various types as 

shown in table 1.21 A Pennsylvania storage facility had 4 magazines, which 

was the largest number among the facilities we visited. Figures 1 through 3 

depict different types of explosives storage magazines. 

 21 Title 27, section 555.203, of the Code of Federal Regulations defines magazine types. 
Page 17 GAO-06-92 Explosives Security 

Figure 1: Type 1 (Permanent Structure) Explosives Storage Magazines in Texas and 

Colorado 

Source: GAO.
Page 18 GAO-06-92 Explosives Security 

Figure 2: Type 2 (Mobile) Explosives Storage Magazines in Pennsylvania and 

Tennessee 

Source: GAO.
Page 19 GAO-06-92 Explosives Security 

Figure 3: Type 3 (Portable Day-Box) Explosives Storage Magazine in Pennsylvania 

All of the 18 facilities contained a variety of high explosives, including C-4 

plastic explosive, TNT, binary explosives, and detonators. Officials from 

13 of the state and local entities provided us with estimates of the 

quantities of explosives they were storing, and they reported amounts 

ranging from 10 to 1,000 pounds, with the majority of the entities (9) 

indicating they had 200 pounds or less. 

At the 18 storage facilities we visited, we looked for the presence of 

exterior and interior fencing, other barriers to restrict vehicle or 

pedestrian access, and security personnel. Federal explosives storage 

regulations do not require any of these physical security attributes; rather, 

the regulations generally require theft-resistant magazine construction 

(including locks) and weekly inspections of magazines. As shown in table 

2, 13 of the 18 storage facilities restricted vehicle access to the facility 

grounds by way of a locked security gate or by virtue of being an indoor 

facility. Five of the 13 facilities restricted vehicle access after normal 

working hours (nights or nights and weekends). Officials at 7 other 

Different Types of Physical 

Security Measures at 

Explosives Storage 

Facilities 

Source: GAO.
Page 20 GAO-06-92 Explosives Security 

facilities said that vehicle access to the facilities was restricted at all times, 

including the indoor facility in Pennsylvania that was located in the 

basement of a municipal building.22 While these outdoor facilities had 

barriers to vehicle access via roadway, not all of the facilities were 

completely surrounded by fencing or some other perimeter barrier, nor do 

federal storage regulations require them to have such a barrier or fencing. 

Table 2: Types of Physical Security in Place at the 18 Explosives Storage Facilities 

We Visited 

Type of physical security 

Number of 

storage 

facilities Examples of physical security 

Exterior barrier around storage 

facility 

 

• Vehicle access restricted 

12

 Fence gates with electronic or manual 

locks 

• All access restricted 

1

 Interior storage in basement of 

municipal building 

• No exterior barrier 5 

Extent of access control 

• Constant 7 24 hours, 7 days a week 

• Certain periods only 5 Nights and weekends, or nights only 

• No access control 5 Accessible at all times by vehicle 

• Extent could not be verified 1a

 

Interior barrier around storage 

magazine 

 

• Pedestrian access restricted 6 Chain-link fences with locked gates 

• All access restricted 1 Multiple interior door locks 

• No interior barrier 11 

Extent of personnel presence 

• Regular patrols or 

inspections 18

 Bomb squad officers and police officers

• 24-hour on-site 9a

 City or county employees 

Source: GAO observation and comments of state and local government officials. 

a

At 1 facility, we were unable to determine the extent of access control or whether a 24-hour 

personnel presence existed. 

 22 At 1 other storage facility in Pennsylvania, we also observed a vehicle barrier in place. 

However, local officials at this facility did not provide information about whether or not the 

barrier was in place at all times. 
Page 21 GAO-06-92 Explosives Security 

Also, as shown in table 2, 6 of 18 storage facilities had an interior barrier 

immediately surrounding their storage magazines to prevent direct access 

by persons on foot. At each of these 6 facilities, the barriers consisted of a 

chain-link fence with a locked gate barring entry by unauthorized 

personnel (figure 4 reflects one of these facilities). At 1 other facility (the 

indoor facility in Pennsylvania), the storage magazines were in the 

basement of the municipal building, and multiple locked doors were used 

to prevent access by unauthorized personnel. Conversely, at 1 facility in 

Texas, the storage magazine could be reached on foot or by vehicle at any 

time because it did not have fencing or vehicle barriers to deter 

unauthorized access. 

Figure 4: Pennsylvania Storage Facility with Interior Barrier Surrounding Type 2 

Storage Magazines 

Officials at all of the 18 storage facilities detailed in table 2 told us that 

official personnel patrolled or inspected the storage facility on a regular 

basis. For example, bomb squad officers said they regularly visited the 

facilities to check on their condition, in addition to visiting the facilities to 

retrieve or place explosive materials in them. In addition to bomb squad 

personnel, officials at 14 of the 18 facilities said that police officers from 

local police departments patrolled the facilities to check for any obvious 

signs of problems such as forced entry. However, these police patrols 

Source: GAO.
Page 22 GAO-06-92 Explosives Security 

typically did not include actual entry into the storage magazines to inspect 

the explosives themselves. 

As further shown in table 2, officials at 9 of the 18 storage facilities we 

visited said that state or local government employees maintained a 24-hour 

presence at the facilities. Four of these storage facilities were located on 

the grounds of police training centers, where either trainees or facility 

personnel were present at all times. Two storage facilities–one each in 

Tennessee and Texas—were on the grounds of jail facilities where local 

correctional personnel worked 24 hours a day, 7 days a week. Two other 

storage facilities were located on the grounds of city/county water or 

sewage treatment plants, and 1 storage facility was located in the 

basement of a municipal building. One additional facility in Pennsylvania 

was located on the grounds of the police academy, but we were unable to 

determine whether there was 24-hour, on-site presence at that facility. 

At the 18 storage facilities we visited, we looked for the presence of a 

monitored alarm or video surveillance system. Although no electronic 

security is required under federal regulations, 4 of the 18 explosives 

storage facilities had either an alarm or a video monitoring system in 

place. Specifically, one entity in Texas had 2 facilities with monitored 

alarm systems in place, and two entities in Pennsylvania and Tennessee 

had video monitoring of their explosives storage facilities. The Texas 

entity had alarm systems in place at 2 of its storage facilities. At 1 facility, 

two small detonator magazines—while not alarmed themselves—were 

located inside a building protected by an alarm system. At a second 

facility, the door to an underground storage magazine was alarmed. 

Regarding the 2 facilities with video monitoring, the Tennessee facility—

which was located on the grounds of a local correctional facility—took 

advantage of a video surveillance system already in place to monitor 

prisoners. The Pennsylvania facility with video monitoring was located 

inside a municipal building and was part of that building’s overall video 

security system. 

The remaining 14 of the 18 storage facilities did not have video or alarm 

systems in place at the time of our visit. Officials at 4 facilities told us they 

had alarm systems planned (funding not yet approved), and officials at 3 

facilities said they had alarm systems pending (funding approved and 

awaiting installation). Officials at 2 facilities also told us they planned to 

install video monitoring. For example, 1 facility in Pennsylvania had its 

video monitoring system destroyed by lightning and was planning to 

Some Explosives Storage 

Facilities Had Electronic 

Security Measures 
Page 23 GAO-06-92 Explosives Security 

replace it. However, the local government authority had yet to approve 

funding for the replacement. 

Several officials commented on the feasibility of installing alarm or video 

monitoring systems at explosives storage facilities. At 4 of the state and 

local entities we visited, officials noted that these storage facilities are 

often located in remote areas without easy access to sources of electricity. 

The officials added that this lack of necessary electrical infrastructure 

could be a cost-prohibitive barrier if they were required to install some 

form of electronic monitoring at explosives storage facilities. Regarding 

the possibility of new storage regulations that would require an electronic 

security system at explosives storage magazines, officials at 9 state and 

local entities told us they would not object to such a requirement as long 

as it did not create an undue financial burden. 

At the 14 state and local entities we visited, we looked for the presence of 

internal inventory procedures, internal or external inspections, and 

licensing of the storage facility by state or local government agencies . 

Under federal regulations, only explosives licensees are required to 

perform periodic inventories and are subject to periodic ATF regulatory 

inspections of their storage facilities; other persons who store explosives 

are not. As shown in table 3, officials at all 14 of the entities we visited told 

us they performed periodic inventories of the contents of their explosives 

storage facilities. Typically, during these inventories, officials said they 

count all the explosives in the storage facility and reconcile them with 

inventory records maintained either manually or in a computerized 

database. 

Inventory and Other 

Oversight Activities Varied 

at Explosives Storage 

Facilities 
Page 24 GAO-06-92 Explosives Security 

Table 3: Inventory and Oversight Activities at the 14 State and Local Entities Visited 

Type of inventory and 

oversight activity 

Number of 

state/local 

entities

Examples of inventory and 

oversight activities 

Internal inventory 

• Annual 7 

• More frequent 7 Conducted monthly, bimonthly, or 

quarterly 

External inspections 

• ATF only 6 All but one conducted voluntarily 

• State or local authority only 1 Conducted by state regulatory 

authority 

• Both ATF and state/local 

authority 

2 Periodic by ATF, plus state/local 

inspection 

• No external inspections 5 

License/permit 

• Required and in place 3 All issued by state regulatory authority 

• Required and not in place 2 Required by state regulatory authority 

• Not required and in place 1 Voluntarily obtained by local police 

• Not required and not in place 8 

Source: GAO observations and comments of state and local government officials. 

In addition, 9 of the 14 state and local entities said they had received 

inspections of their storage facilities, and ATF had conducted the 

inspections in all but 1 of these 9 cases. Regarding this 1 case in 

Pennsylvania, officials said a state government authority regularly 

performed these inspections. With regard to the ATF inspections, state or 

local operators of the selected facilities voluntarily requested these 

inspections in all but 1 case (as discussed further below). 

Of the 9 selected state and local entities that received inspections by a 

regulatory authority, 6 entities told us they received them on a periodic 

basis, with another 3 entities having received a onetime inspection (all by 

ATF). A Pennsylvania entity that said it received annual inspections from 

ATF was unique among those we visited because it had also received a 

onetime inspection from a local government authority. This entity was the 

only one we visited to have any type of inspection, either onetime or 

periodic, from a local government authority. Last, a Colorado entity, 

another of the 5 receiving periodic inspections, said it was being inspected 

on a recurring basis by both ATF and a state government authority—it was 

the only entity we visited that fell into this category. 
Page 25 GAO-06-92 Explosives Security 

Also as shown in table 3, 5 of the 14 state and local entities we visited told 

us they were required to obtain a license from state regulatory authorities 

to operate their explosives storage facilities. One entity in Colorado had a 

license to store explosives issued by the state, and this entity had also 

obtained a federal explosives license issued by ATF. Officials at this 

location told us that the state required them to obtain the federal license 

before applying for its mandatory state license. Indeed, according to ATF 

officials, state or local government facilities may apply for a federal 

explosives license if it is required by their state regulatory agency. 

However, once such a license is issued, these state and local government 

facilities must then comply with all the same explosives laws and 

regulations that are applicable to licensed private sector facilities. 

Officials at the 14 state and local entities we visited commented on the 

feasibility of mandatory ATF oversight of their explosives storage facility. 

Officials at 13 state and local entities said they did not object to the 

possibility of federal licensing or inspection of their explosives storage 

facilities. Six state and local entities also said that they already have close 

contacts with ATF and would not be concerned about additional ATF 

oversight of their storage facilities. Officials at 3 state and local entities 

noted that additional federal oversight was not a concern, as long as they 

were not held to a higher standard of security and safety than ATF 

requires of private industry. 

Two of the 14 state and local entities we visited had previously had a theft 

or loss of explosives from one of their storage facilities. At a storage 

facility in Texas, officials told us that criminals had once used a cutting 

torch to illegally gain entry to an explosives storage magazine. Some 

explosives were stolen, but the suspected thieves were later apprehended 

and the materials were recovered. At another storage facility in Colorado, 

officials said that an unauthorized individual had obtained keys to an 

explosives storage magazine and taken some of the material. As with the 

previous case, several individuals were apprehended and the materials 

were recovered. One of these incidents (the theft of explosives in Texas) 

did not appear in ATF’s nationwide database of reported thefts and 

missing explosives.23

 23 In addition to the two incidents described above, we also identified three other thefts at 

state and local entities during the course of our audit work. These other three incidents 

were all reported to ATF. 

Some Entities Had 

Experienced Explosives 

Thefts or Reported Losses 
Page 26 GAO-06-92 Explosives Security 

The law enforcement community has recently taken action to address the 

issue of thefts and security at law enforcement explosives storage 

facilities. In April 2005, the National Bomb Squad Commanders Advisory 

Board—which represents more than 450 accredited law enforcement 

bomb squads nationwide—initiated a program to increase security 

awareness at its members’ explosives storage facilities. In a letter to its 

membership, the advisory board encouraged all bomb squad commanders 

to increase diligence regarding explosives storage security. The advisory 

board also recommended that all bomb squads request a voluntary ATF 

inspection, ensure they maintain an accurate explosives inventory, and 

assess the adequacy of security measures in place at their respective 

explosive storage facilities to determine whether additional measures 

might be required—such as video monitoring, fencing, and alarms. This is 

a voluntary program, and it is too soon to tell what effect, if any, it will 

have towards enhancing the security at state and local law enforcement 

storage facilities and reducing the potential for thefts. 

At 4 of the 14 state and local entities we visited, we observed various 

storage practices that may not be in compliance with federal explosives 

regulations. These circumstances appeared to be related to storage safety 

issues, rather than storage security. For example, one explosives storage 

facility was located in the basement of a municipal building and utilized 

small type 3 temporary magazines (known as day-boxes) for permanent 

storage of high explosives and detonators. ATF regulations state that these 

magazines should be used only for temporary storage of explosives and 

may not be left unattended. At another storage facility, a high explosives 

storage magazine housed a small detonator (or “cap”) magazine in its 

interior, although ATF regulations generally require detonators to be kept 

separate from other explosive materials. Another storage facility 

contained several boxes of unmarked, 1970s-era plastic explosives 

(specifically C-4), possession of which is generally restricted under federal 

explosives law when the material in question does not contain a detection 

agent. Finally, an official at one storage facility acknowledged that 

because of the weight of explosives currently being stored, their storage 

magazine was in violation of ATF regulations concerning allowable 

distances from other inhabited structures. 

The overall number of state and local government explosives storage 

facilities, the types of explosives being stored, and the number of storage 

magazines associated with these facilities are currently unknown. Further, 

because ATF does not oversee state and local government storage 

Possible Noncompliance 

With Regulations at Some 

Storage Facilities 

Conclusions 
Page 27 GAO-06-92 Explosives Security 

facilities as part of the federal licensing process and ATF does not have 

any other statutory authority to conduct regulatory inspections of these 

facilities, ATF’s ability to monitor the potential vulnerability of these 

facilities to theft or assess the extent to which these facilities are in 

compliance with federal explosives storage regulations is limited. 

Nevertheless, current federal explosives law as enacted by Congress does 

not provide ATF with specific authority to conduct regulatory oversight 

with respect to public sector facilities. And although we did observe 

possible noncompliance with the storage regulations at some of the state 

and local entities we visited, none of these circumstances appeared to 

make the facilities more vulnerable to theft. 

According to ATF’s interpretation of federal explosives laws and 

regulations, state and local government agencies—including law 

enforcement bomb squads and public universities—are required to report 

incidents of theft or missing explosives to ATF within 24 hours of an 

occurrence. However, during the course of our audit work, we identified 

five incidents involving theft or missing explosives at state and local 

government facilities, one of which had not been reported to ATF. 

Because this reporting requirement applies to any “person” who has 

knowledge of a theft from his stock and the definition of “person” does not 

specifically include state and local government agencies, ATF officials 

acknowledged that these entities may be unsure as to whether they are 

required to report under this requirement. On the basis of our limited site 

visit observations and discussions with state, local, and ATF officials, we 

did not identify a specific threat or vulnerability to theft among state and 

local government explosive storage facilities. However, if state and local 

government entities are unsure about whether they are required to report 

thefts and missing explosives, ATF’s ability to monitor these incidents and 

take appropriate investigative action may be compromised by a potential 

lack of information. 

To allow ATF to better monitor and respond to incidents of missing or 

stolen explosives, we recommend that the Attorney General direct the 

ATF Director to clarify the explosives incident reporting regulations to 

ensure that all persons and entities who store explosives, including state 

and local government agencies, understand their obligation to report all 

thefts or missing explosives to ATF within 24 hours of an occurrence. 

Recommendations for 

Executive Action 
Page 28 GAO-06-92 Explosives Security 

On September 9, 2005, we provided a draft of this report to the Attorney 

General for review and comment. 

On September 26, 2005, DOJ advised us that the department had no formal 

agency comments and further advised us that DOJ agreed with our 

recommendation and would take steps to implement it. ATF provided 

technical comments, which we have incorporated into the report, as 

appropriate. 

Unless you publicly announce its contents earlier, we plan no further 

distribution of this report until 30 days after the date of the report. At that 

time, we will send copies of this report to the House Committee on 

Government Reform; House Committee on the Judiciary; House 

Committee on Homeland Security; Senate Committee on the Judiciary; 

Senate Committee on Homeland Security and Governmental Affairs; the 

Attorney General; the Director of the Bureau of Alcohol, Tobacco, 

Firearms and Explosives; appropriate state and local government officials; 

and other interested parties. We will also make copies available to others 

upon request. In addition, the report will be 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) 512-8777 or EkstrandL@gao.gov. Contact points for our Offices of 

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

of this report. Key contributors to this report were William Crocker, 

Assistant Director; David Alexander; Amy Bernstein; Philip Caramia; 

Geoffrey Hamilton; and Michael Harmond. 

Laurie E. Ekstrand 

Director, Homeland Security 

 and Justice Issues 

Agency Comments 

and Our Evaluation 
Appendix I: Scope and Methodology 

Page 29 GAO-06-92 Explosives Security 

In reviewing the security of state and local government explosives storage 

facilities, we focused on the Bureau of Alcohol, Tobacco, Firearms and 

Explosives’ (ATF) role in overseeing and regulating these facilities, 

including the extent to which ATF’s licensing operations address state and 

local government facilities and what authority ATF has to enforce federal 

explosives law and regulations at state and local government facilities. In 

addition, we reviewed the extent to which ATF collects information about 

state and local government facilities, including locations and types and 

amount of explosives stored. To determine what states and localities are 

doing to ensure the safe and secure storage of explosives, we visited state 

and local explosives storage facilities. We also contacted other state and 

local government and explosives industry officials. 

To obtain the perspectives of U.S. government agencies on their efforts to 

regulate and oversee state and local government explosives storage 

facilities, we met with ATF headquarters officials—specifically individuals 

from ATF’s Office of Enforcement Programs and Services, Office of Field 

Operations, Office of Strategic Intelligence and Information, and Office of 

the Chief Counsel. We also met with or obtained information from officials 

with the Department of Justice’s (DOJ) Office of the Inspector General, as 

well as the Federal Bureau of Investigation’s (FBI) Bomb Data Center. 

To determine what selected states and localities were doing to ensure the 

safe and secure storage of explosives in state and local government 

facilities, we met with state and local officials in Colorado, Pennsylvania, 

Tennessee, and Texas—specifically 13 state and local bomb squads and 1 

public university. In these four states, we also contacted other state 

government agencies, including transportation and environmental 

protection agencies and fire marshals. We also contacted other public 

university officials in Arizona, New Mexico, and Utah. 

To obtain additional perspectives of law enforcement and explosives 

industry experts on the safety and security of explosives storage facilities, 

we contacted representatives from the National Bomb Squad Commanders 

Advisory Board, the International Association of Bomb Technicians and 

Investigators, the Institute of Makers of Explosives, the International 

Association of Chiefs of Police, and the National Sheriffs’ Association. 

Appendix I: Scope and Methodology 

Interviews and Other 

Contacts 
Appendix I: Scope and Methodology 

Page 30 GAO-06-92 Explosives Security 

To find out what selected states and localities are doing to ensure the safe 

and secure storage of explosives in state and local government facilities, 

we visited 14 state and local government entities that stored explosives, as 

shown in table 4 below. During these site visits, we met with state and 

local officials and physically observed their explosives storage facilities 

and storage magazines. 

Table 4: State and Local Entities Visited 

State level County level City level 

State Law enforcement Public university Sheriff’s office Police department Fire department

Colorado 1 1 

Pennsylvania 1 3 

Tennessee 1 1 2 

Texas 3 1

Total 2 1 1 9 1

Source: GAO. 

We chose law enforcement bomb squads as the primary focus of our site 

visits because (1) we concluded that state and local bomb squads would 

be the most likely state and local government agencies to have a need for 

explosives storage facilities and (2) there was no other source of 

nationwide information on the number and location of state and local 

government explosives storage facilities. We selected our state and local 

site visits based on the following criteria: 

• In selecting which states to visit, we chose those states most likely to 

have significant state and local government and private sector 

explosives activities. The state selection criteria included (1) the 

number of federally licensed private sector explosives companies, (2) 

the number of reported explosives thefts,1

 and (3) the number of law 

enforcement bomb squads.2

 Using these criteria, we then selected a 

geographic mix of states—specifically one state in the northeast United 

States, one in the southeast, one in the southwest, and one in the west. 

 1

 Based on explosives licensing data compiled by ATF and explosives theft incidents 

reported to ATF, both as of February 2005. 

2

 Based on data about state and local law enforcement bomb squads reported by the 

Bureau of Justice Statistics in November 2000. 

State and Local Site 

Visits 
Appendix I: Scope and Methodology 

Page 31 GAO-06-92 Explosives Security 

• Within each state, we selected state and local bomb squads for our site 

visits. These were chosen to represent a mix based on the type of 

agency, size of jurisdiction, and geographic location. We selected two 

state law enforcement agencies, one county sheriff, nine city police 

departments, and one city fire department. These included three 

jurisdictions with populations over 1 million, five with populations 

between 100,000 and 1 million, three with populations below 100,000, 

and two with statewide jurisdictions. 

• We also selected one non-law enforcement explosives storage facility 

operated by a state university. This facility was selected as typical of 

the various state universities with mining-engineering programs and 

because it had a significant amount of explosives (over 100 pounds) in 

its storage facility. 

During our site visits, we used a semistructured interview guide to conduct 

interviews with state and local officials and determine the level of security 

at their explosives storage facilities. Our criteria for identifying the types 

of security measures in place included existing federal storage laws and 

regulations (27 C.F.R., Part 555, Subpart K) and security guidelines issued 

in 2005 by the explosives industry (the Institute of Makers of Explosives). 

Not all of the security criteria we used are currently requirements under 

federal storage regulations (perimeter fencing, for example). We used 

these additional criteria to demonstrate the wide range of security 

measures actually in place at the time of our visits to these facilities. Also, 

while we were not conducting a compliance audit, during our site visits we 

observed each storage magazine and noted any instances where 

explosives appeared not to be stored in compliance with federal 

regulations. 

We are not disclosing the names or other identifying information relating 

to the individual state and local entities we visited to ensure that securityrelated information is not unintentionally disclosed. Because our review 

was limited to a nonprobability sample of 14 state and local entities in the 

four states, the information discussed in this report is illustrative and 

cannot be generalized to all state and local government entities nationwide 

that store explosives. 

ATF provided data related to explosives licensing and inspections, as well 

as relevant law, regulations, and procedures dealing with the storage of 

explosives. We also obtained data from ATF’s Arson and Explosives 

National Repository related to incidents of theft and missing explosives 

ATF and FBI Data 
Appendix I: Scope and Methodology 

Page 32 GAO-06-92 Explosives Security 

reported to ATF. FBI provided us with a nationwide list of accredited 

bomb squads—including number, location, and name of agency. In 

addition, FBI provided policies and guidance related to the bomb squad 

training and accreditation process. 

The information we obtained from ATF (data on explosives licensees, 

explosives inspections, and explosives thefts) and FBI (data on the 

number and location of bomb squads) was used to provide background 

context on the number of private sector and state and local government 

explosives storage facilities and to assist us in selecting locations for our 

site visits. We interviewed agency officials knowledgeable about the data, 

and as a result, we determined that the data were sufficiently reliable for 

the purposes of this report. We also obtained data from ATF on incidents 

of explosive thefts and missing explosives at state and local government 

storage facilities. On the basis of our site visits and other audit work, we 

determined that these incidents may be underreported, as discussed 

earlier in this report. 

(440368) 
The Government Accountability Office, the audit, evaluation and 

investigative arm of Congress, exists to support Congress in meeting its 

constitutional responsibilities and to help improve the performance and 

accountability of the federal government for the American people. GAO 

examines the use of public funds; evaluates federal programs and policies; 

and provides analyses, recommendations, and other assistance to help 

Congress make informed oversight, policy, and funding decisions. GAO’s 

commitment to good government is reflected in its core values of 

accountability, integrity, and reliability. 

The fastest and easiest way to obtain copies of GAO documents at no cost 

is through GAO’s Web site (www.gao.gov). Each weekday, GAO posts 

newly released reports, testimony, and correspondence on its Web site. To 

have GAO e-mail you a list of newly posted products every afternoon, go 

to www.gao.gov and select “Subscribe to Updates.” 

The first copy of each printed report is free. Additional copies are $2 each. 

A check or money order should be made out to the Superintendent of 

Documents. GAO also accepts VISA and Mastercard. Orders for 100 or 

more copies mailed to a single address are discounted 25 percent. Orders 

should be sent to: 

U.S. Government Accountability Office 

441 G Street NW, Room LM 

Washington, D.C. 20548 

To order by Phone: Voice: (202) 512-6000 

TDD: (202) 512-2537 

Fax: (202) 512-6061 

Contact: 

Web site: www.gao.gov/fraudnet/fraudnet.htm 

E-mail: fraudnet@gao.gov

Automated answering system: (800) 424-5454 or (202) 512-7470 

Gloria Jarmon, Managing Director, JarmonG@gao.gov (202) 512-4400 

U.S. Government Accountability Office, 441 G Street NW, Room 7125 

Washington, D.C. 20548 

Paul Anderson, Managing Director, AndersonP1@gao.gov (202) 512-4800 

U.S. Government Accountability Office, 441 G Street NW, Room 7149 

Washington, D.C. 20548 

GAO’s Mission 

Obtaining Copies of 

GAO Reports and 

Testimony 

Order by Mail or Phone 

To Report Fraud, 

Waste, and Abuse in 

Federal Programs 

Congressional 

Relations 

Public Affairs 

PRINTED ON RECYCLED PAPER