Department of Homeland Security 

Office of Inspector General 

DHS Department-wide Management of 
 

Detection Equipment 
 

(Redacted)
 


OIG-11-47 March 2011 
      

Office of Inspector General 

U.S. Department of Homeland Security 

Washington, DC 20528 

MAR 01 2011

Preface 

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. 

This report addresses the strengths and weaknesses of the department’s management of 

detection equipment. The report identifies measures that the department can take to 

enhance its overall effectiveness. It is based on interviews with employees and officials 

of relevant agencies and institutions, direct observations, and a review of applicable 

documents. 

The recommendations herein have been developed to the best knowledge available to our 

office, and have been discussed in draft with those responsible for implementation. We 

trust that this report will result in more effective, efficient, and economical operations. 

We express our appreciation to all who contributed to the preparation of this report. 

Anne L. Richards 

Assistant Inspector General for Audits 
 

Table of Contents/Abbreviations 

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


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


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


Management of Detection Equipment ...........................................................................5 
 

Recommendations........................................................................................................11 
 

Management Comments and OIG Analysis ................................................................11 
 

Appendixes 

Appendix A: Purpose, Scope, and Methodology.......................................................14 
 

Appendix B: Management Comments to the Draft Report.......................................16 
 

Appendix C: Major Contributors to This Report ......................................................24 
 

Appendix D: Report Distribution ..............................................................................25 
 

Abbreviations 

CBP United States Customs and Border Protection 
 

DHS Department of Homeland Security 
 

DNDO Domestic Nuclear Detection Office 
 

DOD Department of Defense 
 

FAR Federal Acquisition Regulation 
 

FPS Federal Protective Service 
 

HSAR Homeland Security Acquisition Regulation 
 

FEMA Federal Emergency Management Administration 
 

FLETC Federal Law Enforcement Training Center 
 

ICE Immigration and Customs Enforcement 
 

JRC Joint Requirements Council 
 

OCPO Office of the Chief Procurement Officer 
 

OIG Office of Inspector General 
 

PRD Personal Radiation Detector 
 

TASC Transformation and Systems Consolidation 
 

TSA Transportation Security Administration 
 

USCG United States Coast Guard 
 

USCIS United States Citizenship and Immigration Services 
 

USSS United States Secret Service 
 
OIG
 


Department of Homeland Security 

Office of Inspector General 

Executive Summary 

The Department of Homeland Security’s components use detection 

equipment, such as explosive, metal, and radiation detectors, to 

accomplish their respective missions when screening passengers, 

baggage, and cargo. The department spent about $1.3 billion from 

fiscal year 2007 through first quarter fiscal year 2010 to acquire 

this equipment, and the components reported about $3.2 billion of 

detection equipment in their respective inventories. We performed 

this audit to determine whether the department identifies and 

acquires detection equipment in an efficient and effective manner 

to support component mission needs. 

The department can improve management of its detection 

equipment by using strategic sourcing principles that it has applied 

to the acquisition of other commodities, such as law enforcement 

officer firearms and ammunition The department does not have a 

logistics process in place to facilitate strategic sourcing of 

detection equipment. Strategic sourcing would require that 

management standardize equipment purchases for explosive, 

metal, and radiation detection equipment; identify common 

mission requirements among components; and develop standard 

data elements for managing the inventory accounts of detection 

equipment. Improving its management of detection equipment 

will offer the department opportunities to streamline the 

acquisition process and improve efficiencies. 

We are making two recommendations that, if implemented, will 

improve the department’s overall management of detection 

equipment. The department agreed in principle to the 

recommendations and provided information about actions it plans 

to take in response to the recommendations. 

DHS Department-wide Management of Detection Equipment 


Page 1 

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Background 

One of Secretary Napolitano’s top priorities is unifying the 

Department of Homeland Security’s (DHS) 22 components into 

“One DHS.” Secretary Napolitano initiated the DHS Efficiency 

Review as part of her effort to create a leaner, smarter, and more 

efficient department. The Efficiency Review team has identified 

potential efficiencies in the acquisition process by consolidating 

purchases and implementing strategic sourcing as a best practice. 

Strategic sourcing increases acquisition efficiencies and enhances 

mission performance through department-wide acquisitions. 

DHS has eight different procurement offices that purchase 

detection equipment. In 2004, the department created the Office of 

Procurement Operations to provide acquisition services to 

components that did not have a procurement office. Each of the 

remaining seven offices is at the component level, and each has its 

own head of contracting. These components are as follows: 

Customs and Border Protection (CBP) 

Federal Emergency Management Administration (FEMA) 

Federal Law Enforcement Training Center (FLETC) 

Immigration and Customs Enforcement (ICE) 

Transportation Security Administration (TSA) 

United States Coast Guard (USCG) 

United States Secret Service (USSS) 

Components maintain separate inventories for their detection 

equipment. For fiscal year 2010, the components had a combined 

inventory of more than $3.2 billion of detection equipment, most 

of which is deployed. TSA and CBP omitted some equipment 

items in their responses to our data call request. For example, TSA 

did not include its personal and hand-held radiation detectors, and 

CBP did not include its walk-through metal detectors. TSA and 

CBP subsequently provided the inventory data after we determined 

that they were missing from the original submissions and requested 

the data for those items. The components purchased an average of 

about $387 million of detection equipment in each of the last 3 

years, ranging from about $280 million to $511 million. This 

equipment includes metal detectors, explosive detection systems, 

and radiation detectors (including some personal protective safety 

equipment) for screening people, baggage, and cargo at airports, 

seaports, and land ports of entry, as well as federal buildings. 

Figure 1 depicts the department’s universe of detection equipment 

by component as reported by the components, as of March 2010. 

DHS Department-wide Management of Detection Equipment 

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Figure 2 depicts the type and value of detection equipment owned 

by the department as of March 2010. 

The Federal Protective Service (FPS) provides security for the 

nearly 9,000 government buildings managed by the General 

Services Administration. However, FPS uses funds from fees 

collected for protection services to lease or purchase its detection 

equipment. The recent $25 million dollar contract for x-ray 

detection equipment is not part of DHS’ budget, nor does the 

department own any of the equipment FPS uses to carry out its 

mission. Therefore, FPS’ detection equipment is not included in 

the above DHS inventory information. 

DHS Department-wide Management of Detection Equipment 

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DHS’ Office of the Chief Procurement Officer (OCPO) is 

responsible for oversight of most DHS acquisition activities and 

services, including management, administration, and strategic 

sourcing. OCPO responsibilities also include developing and 

publishing department-wide acquisition regulations, directives, 

policies, and procedures. The following are some of the 

regulations and policies OCPO uses to manage its acquisitions: 

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The Federal Acquisition Regulation (FAR) consists of sets 

of regulations issued by federal agencies to govern the 

acquisition process. Components may add their own 

regulation to supplement FAR, including Homeland 

Security Acquisition Regulation (HSAR), which 

establishes uniform policies and procedures for all 

acquisition activities within DHS. 

The Office of Management and Budget Implementing 

Strategic Sourcing Memorandum, dated May 20, 2005, 

directs all federal agencies to leverage spending to the 

maximum extent possible through strategic sourcing. 

The Department of Homeland Security Acquisition 

Manual, issued by the Chief Procurement Officer, 

establishes uniform department-wide acquisition 

procedures, which implement or supplement FAR and 

HSAR. 

According to the Integrated Planning Guide for DHS, to the 

maximum extent possible, components will consider, 

identify, and develop long-term plans to accomplish 

activities and investments using DHS’ Strategic Sourcing 

Program. 

Directive 102-01, Acquisition Management, January 2010, 

consolidates DHS acquisition management policy, 

providing the overall policy and structure for acquisition 

management by prescribing additional management 

procedures and responsibilities that augment existing 

policies, regulations, and statutes. 

In addition, the U. S. Government Accountability Office’s 


“Framework for Assessing the Acquisition Function at Federal 


Agencies” (GAO-05-218G, dated September 2005) identifies 


strategic sourcing as a best practice and notes that one way to 


effectively manage the acquisition process is by empowering 


cross-functional teams. 


DHS Department-wide Management of Detection Equipment 

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Results of Audit 

Management of Detection Equipment 

DHS can better manage the acquisition of detection equipment by 

developing processes based on best practices such as strategic sourcing. 

Strategic sourcing requires standardizing equipment purchases and 

identifying common mission requirements among components. DHS has 

already made progress in using strategic sourcing for a number of 

commodities. Another best practice is developing standard data 

requirements and nomenclature for inventory management. 

Improved management through best practices would offer DHS 

opportunities to streamline the acquisition process, improve efficiencies, 

and provide uniform equipment inventory information. 

Strategic Sourcing 

DHS has established a Strategic Sourcing Program and has applied 

strategic sourcing strategies for many common use items, such as 

firearms, ammunition, and office supplies; however, the 

department is not managing its detection equipment through this 

program. According to DHS officials, components are encouraged 

but not required to use the Strategic Sourcing Program and 

generally do not coordinate and communicate when acquiring 

detection equipment. There is no mechanism in place for 

components to standardize equipment purchases or identify 

common mission requirements among components. For example, 

the department’s Joint Requirements Council is inactive, and 

components do not have the expertise of commodity councils or 

single-item managers to rely on when acquiring detection 

equipment. Further, components view detection equipment as 

unique to their missions and do not attempt to identify common 

mission requirements among other components. This results in 

numerous inefficient purchases by individual components instead 

of consolidated purchases. 

The Office of Management and Budget’s “Implementing Strategic 

Sourcing” Memorandum, dated May 20, 2005, directs all federal 

agencies to leverage spending whenever possible through strategic 

sourcing. Further, according to the DHS Integrated Planning 

Guide, to the maximum extent possible, components will consider, 

identify, and develop long-term plans to accomplish activities and 

investments using the DHS Strategic Sourcing Program. 

DHS Department-wide Management of Detection Equipment 

Page 5 
 

 

DHS has taken steps to unify component purchasing, address 

procurement issues, and improve control and oversight of assets 

through the Transformation and Systems Consolidation (TASC). 

The department plans to integrate financial, procurement, and asset 

management processes under the Chief Financial Officer’s 

Resource Management Transformation Office. According to the 

director of TASC, the department recently awarded a $450 million 

contract for the TASC system. 

Standardizing Equipment Purchases 

Some components did not standardize equipment purchases and 

purchased a variety of different detection equipment models. For 

example, as shown in figure 3, United States Citizenship and 

Immigration Services (USCIS) has 24 and CBP has 21 different 

models of small x-ray equipment, and CBP and USCIS each have 

14 different models of walk-through metal detectors. Due to time 

constraints, we did not quantify the increased administrative and 

logistic support costs incurred by USCIS and CBP by purchasing 

multiple types of equipment on multiple purchase orders. 

However, DHS is incurring higher procurement administrative 

costs and the components increase logistic support costs for 

maintenance, training, and support when they have multiple 

models of equipment to meet similar missions. TSA, which uses 

and maintains the largest inventory of detection equipment in the 

department, should have experienced reduced procurement 

administrative costs and logistic support requirements by 

purchasing and supporting only seven different models of small xray equipment and three models of walk-through metal detectors. 

By limiting the number of models and types of equipment, TSA is 

in a position to increase efficiencies in procurement, maintenance, 

and personnel flexibilities. Figure 3 shows the number of models 

in each of the components’ inventories: 

Figure 3. Number of Models of Detection Equipment 

Component CBP USCIS TSA ICE* 

models models models models 

Small x-ray 21 24 7 5 

Walk-through metal 

detectors 14 14 3 2 

*Not including FPS detection equipment. 
 

Note: Purchase dates for CIS, TSA, and ICE equipment were not readily available.
 


DHS Department-wide Management of Detection Equipment 
 

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Common Mission Requirements 

We identified about $170 million worth of small x-ray machines, 

metal detectors, and personal and hand-held radiation detectors 

that DHS could acquire through strategic sourcing strategies. 

Although multiple components were using similar equipment t o 

meet similar screening missions, each component purchased the 

equipment separately. Components did not coordinate with each 

other to identify common requirements, consolidate purchases to 

gain in buying power, or consolidate logistic support requirements . 

A review of the inventories showed that some components own 

similar models of detection equipment. For example: 

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TSA, CBP, and USCIS all reported similar small x-ray 

machine models in their inventories. 

o	 CBP reported three on hand. 

o	 TSA reported 568 on hand. 

o	 USCIS reported 22 on hand. 

TSA, CBP, ICE, and USCIS reported using similar models 

of walk-through metal detectors, while TSA, CBP, and 

USCIS reported using similar models of walk-through 

metal detectors. 

o	 TSA reported 1,627, CBP reported 10, USCIS 

reported 10, and ICE reported 1 similar models on 

hand. 

o	 TSA reported 121, CBP reported 13, USCIS reported 

10, and ICE reported 2 similar models on hand. 

o	 TSA reported 172, CBP reported 56, and USCIS 

reported 25 similar models on hand. 

Figure 4 shows about $170 million of similar detection equipment 

by component and total item value. 

DHS Department-wide Management of Detection Equipment 

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Figure 4. Inventories of Similar Detection Equipment 

(By Total Estimated Value) 

Small x-ray 

Walk-through Metal 

Detectors 

Personal 

Radiation 

Detectors 

Hand-held 

Radiation 

Detectors 

CBP Est. Value $14,078,098 $ 364,526 $ 23,628,172 $ 20,908,629 

USCIS Est. Value $ 2,679,016 $ 271,500 $ - $ -

TSA* Est. Value $55,019,736 $ 13,371,827 $ 99,450 $ 502,518 

ICE Est. Value $ 264,188 $ 18,800 $ - $ -

USCG Est. Value $ - $ - $ 17,556,000 $ 21,792,000 

Total Est. Value $72,041,038 $ 14,026,653 $ 41,283,622 $ 43,203,147 

 Total Value $ 170,554,460 

Source: Department and component inventories.
 


Unit costs varied for similar equipment and not all inventories included all unit costs. Therefore, the amounts presented are estimates and the value may
 


be understated. 
 

DHS Management Directive 1405, September 2003, established a 

Joint Requirements Council (JRC) as a senior-level requirements 

review board to identify cross-cutting opportunities and common 

requirements among DHS organizational elements for noninformation technology investments. The JRC met periodically 

between fiscal years 2004 and 2006. Representatives on the JRC 

reviewed programs and processes for potential mission overlap and 

redundancies. Among the programs reviewed were TSA’s Secure 

Flight and Registered Traveler and CBP’s Consolidated Registered 

Traveler programs. In 2006, the JRC stopped meeting after the 

department assigned the council chair to other duties and the 

remaining council members did not pursue the potential 

efficiencies. However, DHS now recognizes the importance of the 

JRC and indicated plans to revive the council to identify duplicated 

programs and processes across the department. This undertaking 

should include an effort to identify common data elements and 

nomenclatures within inventories and to establish a data dictionary 

for the department’s detection equipment. 

In addition to the JRC, commodity councils are an integral element 

of developing an effective strategic sourcing program. Commodity 

councils include representatives from across the organization. The 

members act as the subject matter experts in the acquisition 

process and in establishing requirements for a specific commodity 

or service. Generally, the component purchasing the largest 

quantity of a particular item takes the lead role in acquiring the 

DHS Department-wide Management of Detection Equipment 

Page 8 
commodity or service and may serve as that commodity’s singleitem manager. 

DHS and other federal agencies use the commodity council 

concept. For example, in 2003, DHS established the Weapons and 

Ammunition Commodity Council to create a department-wide 

strategy for consolidating requirements and gaining economies of 

scale for the acquisition of weapons and ammunition. The council, 

which includes representatives from each component that uses 

weapons, developed requirements for firearms, ammunition, and 

body armor. ICE took the lead role, using service-level 

agreements with other components to establish one overall 

contract, which is available to all DHS entities. 

The Department of Defense (DOD) is another example of a federal 

department using the commodity council concept. In 2003, DOD 

established the DOD-Wide Strategic Sourcing Program. The 

program established three department-wide commodity councils 

that support the acquisition of the following services: 

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Hand-held wireless communications devices and services, 

led by the U.S. Army and U.S. Air Force 

Clerical support services, led by the U.S. Navy 

Medical health care services, led by the U.S. Army 

Inventory Data 

The inventory systems DHS and its components use are not based 

on standard inventory data elements and standard nomenclature for 

similar detection equipment. Currently, DHS is unable to view 

consolidated inventory information on detection equipment and 

must rely on data calls to determine its inventory, including type, 

model, and value of equipment on hand. Each component 

manages its inventory through eight separate asset management 

inventory systems that do not interface, are not compatible, and do 

not use standardized data descriptions or nomenclatures based on a 

uniform data dictionary. DHS does not have an effort in place to 

identify and assign common data elements to these inventory 

systems. Without a common data dictionary based on common 

data elements and nomenclature, the department does not have 

timely visibility over the on-hand balances. Also, the department 

may not be able to evaluate its detection equipment requirements 

and develop a disciplined logistics function to manage its detection 

equipment. 

DHS Department-wide Management of Detection Equipment 

Page 9 
The “Framework for Assessing the Acquisition Function at Federal 

Agencies” (GAO-05-218G, dated September 2005) emphasizes 

data stewardship as a critical success factor in managing 

information systems. It identifies the need for consistency among 

data definitions, sources, controls, and edits routines as a best 

practice. 

Seven of DHS’ asset management inventory systems are legacy 

systems that existed before DHS. DHS implemented the eighth 

system for headquarters and those components that did not have an 

internal procurement function. The component legacy systems 

support their respective components and continue to operate in a 

stovepipe without interfacing with the department or other 

components. Headquarters relies on data calls from each 

component to gather department-wide inventory information. As 

part of this audit, the components provided us detection equipment 

inventories in response to a data call. The information provided 

was in nonstandard formats, and data elements and nomenclatures 

were not standardized. CBP sent 32,000 lines of data, with some 

entries dated as early as 1940, but its original submission still did 

not include all detection equipment on hand and required a 

followup request to obtain a complete universe. Unless DHS 

establishes a uniform or common data dictionary, the categories 

and data descriptions will vary among the components and the 

department cannot be sure that the inventory data it relies on are 

complete and accurate. For example: 

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One component categorized an explosive detection device 

as “detection equipment,” another categorized it as 

“security equipment,” while another categorized it using 

specific equipment names, with the nomenclature including 

the name of the individual assigned the equipment. 

Personal radiation detectors (PRD) were described as— 

o	 Personal Radiation Detector 

o	 PRD 

o	 Radiation Detector 

o	 Personnel radiation detector, with a corresponding 

name of the person assigned this equipment 

o	 Detector Radiation Personal 

To establish control, oversight, and visibility of the component 

inventories and until DHS deploys an integrated system, it needs to 

establish a common data dictionary to standardize data elements 

across component and headquarters systems. Establishing an 

inventory data dictionary will assist DHS in developing strategic 

DHS Department-wide Management of Detection Equipment 

Page 10 
sourcing strategies and support greater efficiencies in its detection 

equipment inventories. 

Conclusion 

Improved management through best practices will assist the 

department and its components by increasing coordination and 

communication and expanding strategic sourcing strategies into 

detection equipment, which will support Secretary Napolitano’s 

priority of “One DHS.” DHS has taken steps to improve control 

and oversight of assets through the recently awarded TASC 

system. However, DHS needs to establish a standard data 

dictionary, consolidate data descriptions, and make sure 

components use consistent inventory terms before it implements 

the TASC system. 

Recommendations 

We recommend that the Deputy Under Secretary for Management: 

Recommendation #1: Reestablish the Joint Requirements Council. 

Recommendation #2: Establish a commodity council for detection 

equipment, responsible for: 

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Coordinating, communicating, and, where appropriate, 

strategically sourcing items at the department level or 

identifying a single source commodity manager; 

Standardizing purchases for similar detection equipment; and 

Developing a data dictionary that standardizes data elements in 

inventory accounts for detection equipment. 

Management Comments and OIG Analysis 

The department provided written comments, including specific 

comments regarding law enforcement-sensitive information, on 

our draft report. We evaluated these comments and addressed 

them, as appropriate, throughout the report. Below is a summary 

of the department’s written response to our four recommendations 

and our analysis. A copy of the department’s response and a 

summary of its plans and progress for addressing the 

recommendations are included in appendix B. 

The department concurs in principle with recommendations 1 and 

2 but does not concur with recommendations 3 and 4. We 

DHS Department-wide Management of Detection Equipment 

Page 11 
reviewed the department’s comments on recommendation 3 and 

agree with the department’s position noted below that our 

assessment of the department’s acquisition process for radiological 

and nuclear detection equipment described the process for state 

and local acquisitions. Therefore, we removed this 

recommendation along with the corresponding report section from 

the final report. Since the intent of recommendation 4 will be 

included in the action plans for recommendations 1 and 2, 

recommendation 4 is duplicative and has also been removed from 

the final report. Our summary and analysis of the department’s 

official response follows. 

Management Response on Recommendation #1 

The department concurred in principle: The department said it is 

currently assessing alternatives including potentially reestablishing 

the JRC. Upon completion of this assessment, the Chief 

Procurement Officer will provide a copy of the assessment to the 

Inspector General, accompanied by an action plan for 

implementation of the chosen alternative. 

OIG Analysis: We consider the proposed action to be responsive 

to the recommendation. However, this recommendation will 

remain open and unresolved until we receive and review a copy of 

the assessment of alternatives with a corresponding corrective 

action plan and timetable for completion. 

Management Response on Recommendation #2 

The department concurred in principle: The department said that it 

agrees that an analysis of potential strategic sourcing for detection 

equipment is warranted. The department will perform a business 

case analysis of detection equipment by January 31, 2011. A 

commodity council and/or a working group will be established if 

the analysis determines that some or all of this detection equipment 

should be strategically sourced. If this initiative moves forward, 

OCPO will provide OIG with an implementation timeline. 

OIG Analysis: We consider the proposed action to be responsive 

to the recommendation. However, this recommendation will 

remain open and unresolved until we receive and review a copy of 

the strategic sourcing business case analysis and a corresponding 

corrective action plan and timetable for completion if the initiative 

goes forward. 

DHS Department-wide Management of Detection Equipment 

Page 12 
Management Response on Recommendation #3: 

Recommendation #3 requires higher minimum standards for 

radiological and nuclear detection equipment based on Domestic 

Nuclear Detection Office (DNDO) recommendations. 

The department did not concur: The department clarified its 

acquisition process for purchasing radiological and nuclear 

detection equipment and pointed out that the process identified in 

the draft report applies to the acquisition of radiological and 

nuclear detection equipment by state and local governments and 

does not reflect the department’s process. The department noted 

that for DHS radiological and nuclear detection equipment 

requirements, DNDO already collaborates with the respective 

components to determine the appropriate detection equipment that 

meets the particular mission needs and circumstances. 

OIG Analysis: We agree with the department that we outlined 

DNDO’s process for meeting state and local requirements rather 

than federal requirements for purchasing radiological and nuclear 

detection equipment. When we presented the results of our audit 

during multiple discussions with DNDO personnel and other 

component personnel, this distinction was never brought to our 

attention. Since our assessment is not an accurate portrayal of the 

federal process, we removed this recommendation as well as the 

section of the draft report referring to the selection of radiological 

and nuclear detection equipment. 

Management Response on Recommendation #4: 

Recommendation #4 requires updating prescribed internal 

regulatory processes to implement the recommendations above. 

The department did not concur: The department requested that this 

recommendation not be included since the proposed action plan for 

recommendations 1 and 2 does not require regulatory action and 

the action plan for these two recommendations will address 

changes to internal policy and guidance documents. 

OIG Analysis: Since the department plans to address the intent of 

recommendation 4 in its proposed action plans for implementing 

recommendations 1 and 2, this recommendation is duplicative and 

has been removed. 

DHS Department-wide Management of Detection Equipment 

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Appendix A 

Purpose, Scope, and Methodology 

The objective of our audit was to determine whether the 

Department of Homeland Security is identifying and acquiring 

detection equipment in an efficient and effective manner to support 

component mission needs. We performed this audit to address a 

request from Senator Charles Schumer regarding the effectiveness 

of the department’s oversight in identifying and acquiring 

detection equipment to support component mission needs. 

We performed the audit at the department and component levels in 

Washington, DC. Our review included analysis of component 

inventories of detection equipment such as personal radiation 

detectors, hand-held radiation detectors, small x-ray equipment, 

and walk-through metal detectors. 

We interviewed DHS and component officials in the Office of the 

Chief Procurement Officer, including Director, Procurement 

Oversight & Support; Director, Resource Management 

Transformation Office; Director, Strategic Sourcing Division; 

Director, Acquisition Systems; and Assistant Director, Personal 

Property. We also interviewed various officials at the component 

level, including Customs and Border Protection, Transportation 

Security Administration, United States Coast Guard, Immigration 

and Customs Enforcement, and Federal Protective Service. 

We researched applicable laws and regulations and evaluated 

various planned initiatives. We reviewed selected contracts for 

various types of detection equipment owned by components such 

as CBP and USCG (personal radiation detectors) and CBP (walkthrough metal detectors). We examined the inventory reports for 

new equipment, used equipment, and equipment awaiting disposal 

at the TSA Logistics Center as of January 22, 2009, and May 13, 

2010. We did not include detection equipment inventory data for 

FPS, USSS, and FLETC. Specifically, the FPS inventory of 

detection equipment is not funded by the DHS budget, and 

therefore is not owned by DHS. The USSS inventory data posed 

sensitivity issues, and the FLETC inventory is used for training 

purposes and therefore did not meet the audit objective. 

We conducted the audit fieldwork between February and July 2010 

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 on our audit 

objectives. We validated the reliability of inventory data for 

detection equipment by performing limited tests comparing 

DHS Department-wide Management of Detection Equipment 

Page 14 
Appendix A 

Purpose, Scope, and Methodology 

component inventory data with information in the Federal 

Procurement Data System; reviewing selected detection equipment 

contracts; and reviewing recently performed wall-to-wall 

inventories by our Financial Management Division as conducted 

by KPMG auditors. 

DHS Department-wide Management of Detection Equipment 


Page 15 

________________________________________________________________________________________________ 

Homeland

DEC - 62010 Security

MEMORANDUM FOR: Anne L. Richards

~is~t ~s eel r General for Audits

FROM: ~. nderson

Deputy Chief Procurement Officer

SUBJECT: Response to Draft OIG Report DHS Department-wide

Management ofDetection Equipment

In response to your October 22, 2010 memorandum, DRS Department-wide Management of

Detection Equipment - FOR OFFICIAL USE ONLY (FOUO) OIG Project No: IO-IIO-A UDDHS, attached are the Department of Homeland Security (DHS) comments on the draft report.

lfthere are any questions, please contact Mr. David J. Capitano, Office ofthe Chief Procurement

Officer, at (202) 447-5417 or david.capitano@dhs.gov.

Attachment

Appendix B 

Management Comment to the Draft Report 

DHS Department-wide Management of Detection Equipment 


Page 16 

Attachment

Deputy Chief Procurement Officer's Response to Draft OIG Report:

"DHS Department-wide Management ofDetection Equipment"

Deputy Chief Procurement Officer's Response to DIG Report Recommendations

The draft OIG report includes four recommendations. Specific responses to each

recommendation are provided below.

Recommendation I: "Reestablish the Joint Requirements CounciL"

Response: Concur in Principle. The Department is currently assessing alternatives in this

area, including potential reestablishment ofthe Joint Requirements Council (JRC). Upon

completion of this assessment, CPO will provide a copy ofthe assessment to the IG,

accompanied by an action plan for implementation of whatever alternative is chosen.

Recommendation 2: "Establish a commodity council for detection equipment, responsible

for:

• Coordinating, communicating, and, where appropriate, strategically sourcing items at

the department level or identifying a single source commodity manager;

• Standardizing purchases for similar detection equipment; and,

• Developing a data dictionary that standardizes data elements in inventory accounts for

detection equipment."

Response: Concur in principle. DHS agrees that an analysis of potential strategic sourcing

for detection equipment is warranted. As such, the department will perfonn a strategic

sourcing business case analysis of detection equipment. Ifthat analysis yields a

detennination that some or all of this equipment should be strategically sourced, a

commodity council andlor a working group will be established. The estimated timeline for

completion ofthe business case analysis is January 31, 2011. Should the business case yield

a detennination that the initiative move forward, the Office of the Chief Procurement Officer

will provide the IG with a timeline for implementing our strategic sourcing process for this

initiative.

Recommendation 3: "Require higher minimum standards for radiological and nuclear

detection equipment based on DNDO recommendations."

Response: onconcur. The draft report contains a fundamental misunderstanding of the

differences between the Department's acquisition of radiological and nuclear detection

systems for DHS Components, as opposed to the purchasing ofradiological and nuclear

detection systems by state and local law enforcement agencies using FEMA grant funds. The

process outlined in lhe draft report subsection entitled "Departmental Oversight" prescribes

the role of DNDO, and the process used by state and local law enforcement organizations to

acquire radiological and nuclear detection systems. For DHS requirements, DNDO

collaborates with the requiring organization (e.g., CBP) to determine the appropriate

radiological and nuclear system that meets the particular needs/circumstances. Furthennore,

2

Appendix B 

Management Comment to the Draft Report 

DHS Department-wide Management of Detection Equipment 
 

Page 17
 

Attachment

Deputy Chief Procurement Officer's Response to Draft DIG Report:

"DHS Department-wide Management ofDetection Equipment"

implementation of Recommendations 1 and 2 will provide additional assurance that the

Department's acquisition and management of detection equipment includes the selection of

the most appropriate products for its mission needs, as facilitated by the input of DNDD and

other components; therefore, we request that this recommendation not be included in the

OIG's fmaI report.

Recommendation 4: "Update prescribed internal regulatory processes to implement the

recommendations above."

Response: Nonconcur. The proposed action plan for implementing Recommendations I and

2 ofthe draft report does not require "regulatory" action (such as revisions to the Department

ofHomeland Security Acquisition Regulations). While any process changes must

accompany our actions related to Recommendations 1 and 2, our action plans with respect to

Recommendations J and 2 will ensure implementation ofthese items, including all necessary

internal policy and guidance documents. Therefore, we request that this recommendation not

be included in the OIG's final report.

Comments on Report Content

The following comments are provided in accordance with the draft report sections as

specified below. Under separate memorandum, we have provided comments regarding the

Department's concerns with respect to the release of certain information included within this

report to the general public; specifically, because release ofthis information raises the risk of

law enforcement circumvention (i.e., is law enforcement sensitive and therefore exempted

from release, pursuant to 5 USC 552 82, 87(e)).

J. Section entitled "'Executive Summary". Page J

A. General Comment:

Draft Report Language: The draft report does not include an adequate or complete

definition of detection equipment. Although basic types of detection equipment are

mentioned with this section, there is no definition of detection equipment that compliments

the scope ofthe DIG's audit.

Comment: Recommend the inclusion of a definition of detection equipment in the final

report, similar to the following:

"tn common law enforcement terms, "detection equipment" can be defined as an

instrument or machine that will allow an officer to determine the specific type, class or

nature ofmaterial, object or organism that is sequestered from view and not under the

3

Appendix B 

Management Comment to the Draft Report 

DHS Department-wide Management of Detection Equipment 
 

Page 18
 

Attachment

Deputy Chief Procurement Officer's Response to Draft DIG Report:

"DHS Department-wide Management ofDetection Equipment"

direct view ofthat officer. Within the context ofthis report the tenn "detection

equipment" refers to a specific type of instrument or apparatus that is designed

specifically to detennine whether or not a conveyance or person is carrying a material

that is emitting radiation. A number ofthese instruments have been designed not only to

detennine the presence ofsuch radioactive emissions but also to identify the radioisotope

that is present and causing the emissions."

B. Page I. second paragraph. fourth sentence:

Draft Report Language: "Without departmental oversight, some components have not

always acquired the best-performing personal and hand-held radiological and nuclear

detection equipment available to meet mission needs and ensure the safety ofofficers in the

field."

Comment: Recommend the removal of this sentence from the final report, because this

statement is derived from the draft report subsection entitled "Departmental Oversight,"

which includes a fundamental misunderstanding of the differences between the Department's

acquisition ofradiological and nuclear detection systems for DHS Components, as opposed

to the purchasing ofradiological and nuclear detection systems by state and local law

enforcement agencies using FEMA grant funds. Alternative language for the draft report

subsection entitled "Departmental Oversight" is included below.

2. Section entitled f'Background." pages 2 through 5:

A. Page 2. third paragraph. second sentence.

Draft Report Language: "Forfiscal year 2010, the components had a combined inventory

ofover $3.2 billion ofdetection equipment."

Comment: Request the revision of this sentence to reflect the fact that most ofthis inventory

has been deployed and is not stored in warehouses. Recommended revised language is as

follows:

"For fiscal year 20 I0, the components had a combined inventory of over

$3.2 billion of detection equipment, a majority of which is deployed."

B. Page 2. third paragraph. third and fourth sentences.

Draft Report Language: "TSA and eBP omitted some equipment items in their responses

to our data call request. For example, TSA did not include its personal and hand-held

radiation detectors, and eBP did not include its walk-through metal detectors."

4

Appendix B 

Management Comment to the Draft Report 

DHS Department-wide Management of Detection Equipment 
 

Page 19
 

Attachment

Deputy Chief Procurement Officer's Response to Draft OIG Report:

"DHS Department-wide Management ofDetection Equipment"

Comment: Request the revision of these sentences to reflect that, although certain

equipment was not included in response to the DIG's original data call, in response to a

subsequent data call inventory data for this equipment was provided to the audit team.

C. Page 4. first complete paragraoh. first sentence.'

Draft Report Language: "DHS' Office ofthe ChiefProcurement Officer (OCPO) is

responsible for all DHS acquisition activities and services, including management,

administration and oversight, financial assistance, and strategic and competitive sourcing."

Comment: Recommend revising this sentence to correctly represent the role of OCPO.

While OCPO is responsible for the oversight of most DHS acquisition activities, it is not

responsible for financial assistance (the Office ofthe Chief Financial Officer is responsible

for financial assistance). Therefore, we recommend the following or similar language to

replace the current sentence:

"DHS's Office of the Chief Procurement Officer (OCPO) is responsible for oversight of

most DHS acquisition activities and services, including management, administration,

oversight, and strategic sourcing."

3. Section entitled "Results ofAudit. "pages 5 through 14:

A. Page 7, Figure 3. second fOotnote.'

Draft Report Language: "··CBP did not include walk-through metal detectors in

inventory numbers provided to us. "

Comment: Request the revision ofthis footnote to reflect that, although certain equipment

was not included in response to the DIG's original data call, in response to a subsequent data

call inventory data for this equipment was provided to the audit team.

B. Page 8. Figure 4. fOotnote:

Draft Report Language: "·CBP and TSA omitted itemsfrom their reported inventory. CBP

did not include walk-through metal detectors, and TSA did not report any personal radiation

detectors. "

Comment: Request the revision ofthis footnote to reflect that, although certain equipment

was not included in response to the DIG's original data call, in response to a subsequent data

call inventory data for this equipment was provided to the audit team.

5

Appendix B 

Management Comment to the Draft Report 

DHS Department-wide Management of Detection Equipment 
 

Page 20
 

Attachment

Deputy Chief Procurement Officer's Response to Draft OIG Report:

"DHS Department-wide Management ofDetection Equipment"

C. Page 1/. subsection entitled "Departmental Oversight":

Draft Report Language: "Departmental Oversighl- DHS needs to improve its oversight of

detection equipment by taking a stronger leadership role over the selection ofradiological

and nuclear detection equipment. The department only requires components to select

radiological and nuclear detection equipment which meet minimum standards. Congress

mandated that the Domestic Nuclear Detection Office (DNDO) set Technical Capability

Standards and implement a test and evaluation program for radiological and nuclear

detection equipment. However, DNDO does not make recommendations or rank test results

on the types ofequipment the components purchase. As a result, the department may not be

fully using the expertise ofDNDO personnel and components may be acquiring detection

equipment that may not be the most effective or provide the greatest protection for itsfront

line officers. In 2005, National Security Presidential Directive 43 and Homeland Security

Presidential Directive 14 created the Domestic Nuclear Detection Office (DNDO) to expand

and improve radiological and nuclear detection capabilities. Congress mandated DNDO to

set Technical Capability Standards and to implement a test and evaluation program. The

test and evaluation program provides aframeworkfor testing radiological and nuclear

detection equipment. The framework provides performance, suitability, and survivability

information, and related testing for preventive radiological and nuclear defection equipment.

However, the scientific community has not yet accepted DNDO 's framework as an industry

standard. Currently, the American National Standards Institute (ANSI) N42 standards are

the minimum performance baseline for radiation detection equipment. DNDO is responsible

for the acquisition ofradiological and nuclear detection equipmentfor DRS and receives

directfundingfor these equipment purchases. However, according to senior officials at

DNDO, it cannot make recommendations, but can only provide unranked test results and

capabilities 0/the types ofmodels available to the components. DNDO is required to

acquire the equipment the component selects as long as it meets the minimum standard/or

radiological and nuclear detection equipment. DNDO's mission is to expand and improve

radiological and nuclear detection capabilities. Allowing the components to select an

equipment model that only meets the minimum standards when improved technology is

available may impede DNDO's mission and does not ensure that DHS is providing the best

available equipment to its/rontline officers. For example, components use PRDs as a

passive, first alert radiation indicator to protect personnel. Two components that use this

equipment use different types and have different approaches to its use and issue,

The hand-held radiation detector is another type 0/

6

Appendix B 

Management Comment to the Draft Report 

DHS Department-wide Management of Detection Equipment 
 

Page 21
 

Attachment

Deputy Chief Procurement Officer's Response to Draft OIG Report:

"DHS Department-wide Management ofDetection Equipment"

equipment that the components purchase that only needs to meet minimum standards (ANSI).

These devices, which identifY the fype ofradiation emittedfrom a detected radioactive

source, are designed to detect both gamma and neutron rays. I

Response: Recommend this subsection be deleted because it is inaccurate. DNDO

purchases all radiological and nuclear detection equipment for CSP and the other DHS

Components. The draft report contains a fundamental misunderstanding of the differences

between the Department's acquisition ofradiological and nuclear detection systems for DHS

Components, as opposed to the purchasing of radiological and nuclear detection systems by

state and local law enforcement agencies using FEMA grant funds. This subsection also

includes the following erroneous statement "The department only requires components to

select radiological and nuclear detection equipment which meet minimum standards." There

is no such departmental requirement. Further, DNDO is not bound by policy or law to only

procure equipment that meets minimum standards, yet this subsection suggests that this is the

current DHS practice. Therefore, we recommend the following or similar language be

inserted in lieu of the entire subsection in the draft report:

Departmental Oversight

DNDO conducts all acquisitions for radiological and nuclear detection equipment

on behalf ofthe various DHS components. The DNDO acquisition process for

radiological and nuclear detection equipment for DHS components is divided into

two parts; one for legacy and one for next generation systems. When DNDO was

created in 2005, DHS components were already acquiring various radiological

and nuclear detection devices based upon threat and operational considerations as

known prior to or in the fonnative years ofDHS. These legacy systems were

deployed; users were trained; and maintenance chains were set in place. DNDO

has, and will, continue to procure these legacy systems, based upon joint

acquisition plans from each component while next generation systems are

developed, as necessary.

For new detector systems, such as the recently completed Advanced Handheld,

the acquisition process is quite different. DNDO is the lead for any new

radiological and nuclear detection system acquisitions for DHS. DNDO works

with the component(s) to define a set ofrequirements that both meet the

7

Appendix B 

Management Comment to the Draft Report 

DHS Department-wide Management of Detection Equipment 
 

Page 22
 

8

DHS Department-wide Management of Detection Equipment 
 

Page 23
 


Attachment

Deputy Chief Procurement Officer's Response to Draft DIG Report:

"DHS Department-wide Management ofDetection Equipment"

operational need ofthe end-user(s) and the technical effectivness needs ofDNDO.

Special consideration is paid to selecting requirements to develop a common

system that can be operated by multiple components. DI DO technical

requirements are based upon a combination of threat guidance and pathway

analysis provided by the Global Nuclear Detection Architecture. New detectors

are subject to rigorous testing including an independent Operational Test, which

substantiates usability and effectiveness. Next generation systems can be either

custom systems developed for specific solutions or they can be commercial-ofTthe-shelfsystems, which provide the necessary features and functions.

Appendix B 

Management Comment to the Draft Report 
Appendix C 

Major Contributors to This Report 

Linda Howard, Director 

Sam Bellino, Audit Manager 

Patricia Benson, Auditor-in-Charge 

Paul Exarchos, Program Analyst 

Falon Newman-Duckworth, Program Analyst 

Enrique Leal, Program Analyst 

Jeffrey Balsewicz, Program Analyst 

Anthony Colache, Independent Referencer 

DHS Department-wide Management of Detection Equipment 
 

Page 24
 

Appendix D 

Report Distribution 

Department of Homeland Security 

Secretary 

Deputy Secretary 

Chief of Staff 

Deputy Chief of Staff 

General Counsel 

Executive Secretariat 

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 

Office of Management and Budget 

Chief, Homeland Security Branch 

DHS OIG Budget Examiner 

Congress 

Congressional Oversight and Appropriations Committees, as 

appropriate 

DHS Department-wide Management of Detection Equipment 
 

Page 25
 

ADDITIONAL INFORMATION AND COPIES 

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fax your request to (202) 254-4305, or visit the OIG web site at www.dhs.gov/oig. 

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