Department of Homeland Security
 

Review of Allegations of Misconduct and 

Mismanagement Within TSA’s 

Office of Global Strategies 

(Redacted) 

OIG-12-96 July 2012
 
Office of Inspector General 

U.S. Department of Homeland Security 

Washington, DC 20528 

July 2, 2012

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. 

The Administrator, Transportation Security Administration, asked that we review several 

allegations of management misconduct and program mismanagement within the Office of 

Global Strategies. Our review focused on these allegations as well as related administrative 

and operational issues. 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 this report will result in more effective, efficient, and economical operations. We 

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

Charles K. Edwards 

Acting Inspector General 
Executive Summary .............................................................................................................1 

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

Results of Review ................................................................................................................5 

OGS Took Corrective Actions on Assessments Conducted in Haiti .............................6 

TSA Did Not Issue a Timely Emergency Amendment for Haiti .................................11 

Recommendation .........................................................................................................15 

Management Comments and OIG Analysis ................................................................15 

TSA Has Not Evaluated Passenger Screening Procedures at 

All Preclearance Airports ..........................................................................................16 

Recommendation .........................................................................................................20 

Management Comments and OIG Analysis ................................................................20 

Creation of the Regional Director Position Raised Concerns ......................................21 

TSAR Positions Are Properly Placed ..........................................................................27 

The Effectiveness of Capacity Development Programs Is Difficult To Measure .......31 

Perceptions of Discrimination, Favoritism, and the Abuse of Power Do Exist ...........33 

Appendices 

 Appendix A: Purpose, Scope, and Methodology.......................................................49 

Appendix B: Recommendations ................................................................................51 

Appendix C: Management Comments to the Draft Report .......................................52 

Appendix D: Current TSAR Locations and Areas of Responsibility ........................55 

Appendix E: TSARs With Responsibility for the Caribbean ....................................58 

Appendix F: Major Contributors to this Report ........................................................60 

Appendix G: Report Distribution ..............................................................................61 

Table of Contents/Abbreviations 
 

 

 

 

 

 

Abbreviations 

ASSIST Aviation Security Sustainable International Standards Team

BMO Business Management Office

CAP Cap Haitian International Airport 

CBP Customs and Border Protection 

CDB Capacity Development Branch 

DHS Department of Homeland Security

EA Emergency Amendment

EEO Equal Employment Opportunity

FY fiscal year

GAO Government Accountability Office

GC Global Compliance

GPP Global Policy and Programs 

ICAO International Civil Aviation Organization 

IIR International Industry Representative

IO International Operations

IPS Integrated Plans and Support 

MSPB Merit Systems Protection Board

NSDD National Security Decision Directive 

OCC Office of Chief Counsel

OGS Office of Global Strategies 

OIG Office of Inspector General

OSO Office of Security Operations

PAP Toussaint L'Ouverture International Airport

RIPR Risk/Incident-Driven Policy Review

SARP Standard and Recommended Practices

SD Security Directive

SOP Standard Operating Procedure 

TSA Transportation Security Administration 

TSAR Transportation Security Administration Representative

TSNM Transportation Sector Network Management 

TSS Transportation Security Specialist
 

 

 

 

OIG
 Department of Homeland Security 

Office of Inspector General 

Executive Summary 

On May 18, 2011, Transportation Security Administration (TSA) 

Administrator John Pistole received a letter from an anonymous author 

who made several allegations of misconduct and mismanagement 

within TSA's Office of Global Strategies. Administrator Pistole asked 

us to review the allegations. 

The author provided only a general description of the allegations and 

little or no supporting information or examples, and appeared to have 

little understanding of some of the policies or programs implicated in 

the allegations. The allegations fell into three broad categories: 

security concerns, waste and inefficiency, and workplace issues.

We were unable to substantiate most of the author's allegations. Office

of Global Strategies took corrective actions on assessments conducted 

in Haiti, is methodical in determining where to deploy its 

representatives around the world, and did not circumvent the hiring

process or take improper actions to select two regional directors. The

Capacity Development Branch has spent thousands of dollars on its 

training programs, but the allegation that its programs provide little

more than basic screener training is inaccurate. However, we 

confirmed that TSA did not issue a timely Emergency Amendment for 

Haiti following the 2010 earthquake, and has not evaluated all

preclearance airports as required. Office of Global Strategies is taking

action to strengthen the Emergency Amendment process and the 

preclearance program.

We did not identify any discrepancies or evidence of favoritism 

regarding Office of Global Strategies' administration of awards, 

promotions and in-position increases, training, and hiring processes, but 

some employees perceive problems in these areas. Many employees 

claimed to be fearful of retaliation, but few said they actually

experienced it. We have made two recommendations in this report. 

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Background

In October 2007, the TSA established the Office of Global Strategies 

(OGS) to consolidate all TSA international activities under one office, 

streamline operations, and ensure a cohesive approach in support of 

TSA's international aviation security mission. TSA brought together 

under the direction of one Assistant Administrator personnel from 

several offices, including the Office of Transportation Security Policy,

the Office of Security Operations (OSO), Transportation Sector 

Network Management (TSNM), and Maritime and Land Security.

OGS' mission is to develop and promote the implementation of 

effective/enhanced global transportation security processes and 

structures worldwide while ensuring compliance with international 

and TSA standards. To accomplish this mission, OGS works with 

foreign partners and transportation entities operating overseas by

identifying risk through compliance assessments and inspections, 

mitigating risk through capacity development and outreach/engagement, 

and responding to international incidents as they occur.

OGS currently has approximately 240 personnel operating at various 

domestic and international locations, and is organized into five 

divisions:

• Global Compliance (GC) evaluates foreign airport security

postures in accordance with recognized security standards

established by the International Civil Aviation Organization 

(ICAO), a specialized agency within the United Nations. The 

division is also responsible for conducting assessments on 

foreign and domestic air carriers that provide international 

service to the United States. To carry out its responsibilities 

for conducting foreign airport and air carrier assessments, GC

employs Transportation Security Specialists (TSSs) who 

operate out of one of the five Regional Operations Centers. 

• International Operations (IO) executes TSA's international 

outreach and engagement strategy. To carry out its mission, IO 

employs Transportation Security Agency Representatives 

(TSARs). TSARs are stationed at diplomatic posts and serve 

Review of Allegations of Misconduct and Mismanagement Within TSA's Office of Global Strategies 

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as agency representatives to foreign governments and their 

aviation authorities. They liaise with foreign governments to 

initiate corrective actions and mitigate security deficiencies

identified in GC's foreign airport assessments, ensuring that 

foreign air transportation systems meet international standards 

for aviation security. TSARs also work toward the immediate

implementation of enhanced security measures to counter 

terrorism threats not originally identified when international 

aviation security standards were developed.

•	 Global Policy and Programs (GPP) is the primary aviation 

security policy office in OGS. GPP is divided into three 

branches. The Global Policy and Programs Branch develops 

transportation security processes. The International Air Carrier

Program Branch consists of a group of International Industry

Representatives (IIRs) who serve as the primary liaison 

between TSA and foreign air carriers and foreign all-cargo

carriers regarding aviation security matters. The Cargo Branch 

advises OGS leadership on air cargo security matters and 

manages OGS involvement in international air cargo security

programs.

•	 Integrated Plans and Support (IPS) serves both an operational 

and internal support mission. IPS is divided into four 

branches. The Capacity Development Branch (CDB) provides 

targeted assistance to foreign aviation security partners in 

countries where aviation security assistance is necessary for the 

enhancement of security or where measures in place do not 

meet either international or U.S. standards. The Training and 

Development Branch manages OGS employee training and 

professional development programs. The Rapid Response 

Branch manages OGS critical incident or disaster response 

operations. The Risk/Systems Branch supports OGS by

managing technical innovation and risk analysis programs.

•	 Business Management Office (BMO) oversees resources and 

services in support of OGS operational readiness. It is divided 

into Human Resources, Budget, and Logistics branches.

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In response to new challenges in securing inbound international 

flights, most notably the failed 2009 Christmas Day bombing, 

Congress has allocated additional resources to OGS. For example, in 

fiscal year (FY) 2011, Congress provided an additional $32.2 million 

to fund 74 new positions to enhance and manage international 

programs at 25 offices in high-risk areas, in order to train host nations 

to mitigate vulnerabilities and ensure that they comply with 

international aviation standards. In FY 2012, OGS plans to hire an 

additional 53 personnel, including seven Supervisory TSSs and 35 

TSSs, when funds become available. 

The Allegations

On May 18, 2011, TSA Administrator Pistole received a letter from an 

anonymous author who made several allegations of misconduct and 

mismanagement within OGS. The author also wrote that many

believe that TSA's Deputy Administrator knew misconduct and 

mismanagement existed and withheld information from the TSA 

Administrator. 

The author provided only a general description of the allegations and 

little or no supporting information or examples, and appeared to have 

little understanding of the many policies or programs implicated in the

allegations. The author remained anonymous during this review. 

Based on what we could infer from the letter, the allegations fell into 

three categories:

1.	 Security concerns resulting from the failure to- 

•	 Take corrective actions with regard to TSA assessments 

conducted in Haiti;

•	 Issue Emergency Amendments in a timely manner; and 

•	 Address deficiencies at preclearance airports promptly.

2.	 Waste and inefficiency due to the- 

•	 Creation of the Regional Director position; 

•	 Random placement of TSARs;

•	 Programs administered by CDB; and

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•

•

•

•

 

 

 

Volume of unnecessary travel.

3. Workplace issues involvingDiscrimination; 

Favoritism; and

Abuse of power

Results of Review

We were unable to substantiate most of the anonymous author's allegations. OGS

took corrective actions on assessments conducted in Haiti, is methodical in 

determining where to deploy its representatives around the world, and did not 

circumvent the hiring process or take improper actions to select two regional 

directors. CDB has expended significant resources on training, and the allegation that 

its programs provide little more than basic screener training is inaccurate. We

confirmed that TSA did not issue a timely Emergency Amendment for Haiti after the 

2010 earthquake and that TSA has not evaluated all preclearance airports. TSA is 

taking action to strengthen the Emergency Amendment process and the preclearance 

program. We also determined that OGS follows a thorough process to evaluate, 

select, and deploy TSARs. 

Immediately after we initiated our review, several current and former employees 

contacted us to talk about their experiences in OGS. Employees were less concerned 

about the "security� and "waste and inefficiencies� issues raised in the email-some

challenged that these were even issues-and were much more interested in discussing

possible acts of discrimination, favoritism, and abuse of power. We engaged with 

employees at all levels of OGS to gain a better understanding of the work environment

and how OGS carries out its mission. We seldom heard concerns about how OGS 

accomplishes its aviation security responsibilities. 

Some employees made allegations against specific supervisors or managers.

Although we obtained a general understanding about those situations, we did not 

review these individual allegations in depth because the determination of whether one 

employee was retaliated against, discriminated against, or favored over another is a 

complex matter that may not be resolved until reviewed by the Equal Employment 

Opportunity Commission, Merit Systems Protection Board (MSPB), or a court of 

law. Overall, employees' opinions of management were mixed, although few 

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employees complained that OGS is not carrying out its aviation security

responsibilities adequately.

OGS Took Corrective Actions on Assessments Conducted in Haiti 

The author of the letter characterized OGS' involvement in Haiti after the 

January 2010 earthquake as "disastrous.� The author alleged that, although

numerous deficiencies in critical areas were identified, OGS failed to follow 

its own security policies and procedures and, most important, failed to take 

immediate action to correct identified vulnerabilities. This, the author

alleged, meant that the Haitian airports operated with great risk and 

vulnerabilities for months. To protect sensitive security information, the 

author did not provide any details. 

Based on the security assessments OGS conducted in Haiti, the actions OGS 

has taken to address the deficiencies identified in those assessments, and 

additional actions OGS has taken in Haiti, we determined that TSA took 

appropriate corrective actions in Haiti.

OGS Deployed Incident Response Teams to Haiti After the

Catastrophic Earthquake in January 2010

The Republic of Haiti has two international airports that operate flights 

to the United States. Toussaint L'Ouverture International Airport 

(PAP) in the capital city of Port-au-Prince is the country's primary

airport, offering commercial air service by major U.S. and 

international air carriers. PAP security staff includes 165 Security

Agents and 15 supervisory staff. Cap Haitian International Airport 

(CAP) is located in the northern coast city of Cap Haitian. CAP, 

which operates a small number of charter and cargo carrier flights to 

the United States, is staffed by 20 Security Agents and five 

supervisors. 

On January 12, 2010, a catastrophic earthquake struck Haiti. The

magnitude 7.0 earthquake's epicenter was approximately 16 miles 

southwest of Port-au-Prince. This earthquake caused extensive 

damage to buildings and infrastructure, including significant damage

to PAP. The Haitian Government reported that between 217,000 and 

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230,000 people died, and estimated that 1 million people were left 

homeless. 

On January 13, 2010, OGS activated a Crisis Incident Management 

Group. TSA's mission in response to the earthquake was to protect 

passengers traveling on U.S. and non-U.S. aircraft operating to and 

from the United States. After the earthquake, OGS deployed "Go 

Teams� to Port-au-Prince and Santo Domingo, Dominican Republic. 

The Go Team deployed to Santo Domingo, which arrived on January

19, 2010, provided aviation security oversight at Las Americas 

International Airport and coordinated with the Department of State for

the evacuation of U.S. citizens from the U.S. Embassy in Haiti to San 

Ysidro Air Base in Santo Domingo. After conducting an initial airport 

security assessment, the Go Team noted no security deficiencies at

either Las Americas International Airport or San Ysidro Air Base. 

The Go Team operating in Santo Domingo departed January 28, 2010.

The Go Team assigned to PAP in Port-au-Prince arrived on January

20, 2010. After its initial assessment of PAP security operations, the 

Go Team identified the following problems: 

 The Haiti Go 

Team's efforts included establishing security checkpoints to conduct 

evacuee operations, assisting in perimeter control, reducing tarmac 

congestion, providing logistical support, facilitating incoming relief 

supplies, and assisting in the restoration of commercial flight 

operations at PAP. On February 3, 2010, TSA screening equipment 

and technology were deployed to PAP by military aircraft. This 

shipment included five x-ray machines, five walk-though metal 

detectors, three explosive trace detection machines, 25 handheld metal 

detectors, and 60 storage bins for passengers' use at the x-ray

screening stations. Beginning on February 9, 2010, OGS staff trained 

89 Haitian National Airports Authority security employees and 15 

U.S. Air Force personnel on how to set up a checkpoint and how to 

calibrate and operate the screening equipment. 

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On February 19, 2010, limited commercial air service from PAP to the 

United States was resumed. Over the next few days, the Go Team 

observed security operations for the screening of commercial flights to 

the United States, and made on-the-spot adjustments to procedures 

until the Go Team's post-earthquake assistance at PAP ended on 

February 21, 2010.

OGS Took Actions To Address Security Concerns 

OGS conducted an assessment of PAP from March 24 through April 2, 

2010. The assessment team concluded that most security measures at 

PAP did not meet minimum international security standards for civil 

aviation. The team identified five of the critical ICAO Standard and 

Recommended Practices (SARP) categories as deficient. 

 The assessment team

documented security deficiencies in the following categories:

In August 2010, OGS initiated the Aviation Security Sustainable 

International Standards Team (ASSIST) program for Haiti to improve

aviation security procedures and raise the security level in Haiti to

international standards.2

 The Haiti ASSIST program employed a twophase approach. The first phase focused on mitigating the critical 

SARPs identified in the March 2010 Foreign Airport Assessment 

2

 See p. 31 for a detailed description of the ASSIST program.

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Report.3

 The second phase is to advance the long-term sustainability

of Haitian aviation security programs. Although the program aims to 

enhance the security posture at both Haitian airports, OGS has focused 

most of its resources on PAP, the nation's major international airport 

as PAP has a significantly larger volume of commercial service to the

United States than CAP. 

From October 13 to 24, 2010, and with the assistance of Transport 

Canada and the Canadian Air Transport Security Authority, OGS 

conducted ASSIST Security Screener Training at PAP. Screening 

techniques training included instruction on improving security

procedures to identify and prevent the introduction of prohibited items 

onto aircraft and in secure areas. ASSIST trainers presented a 

screening instructor skills course to five security supervisors and two 

National Airports Authority security operations employees. It was 

OGS' intent to certify local screening instructors to train the National 

Airports Authority screening workforce. The newly certified Haitian 

security instructors, with support from ASSIST staff, then provided 

screening techniques training for eight National Airports Authority

Security Agents. Following screener training, the ASSIST team 

provided management training to 14 screening supervisors.

OGS conducted a foreign airport assessment of PAP approximately

1 year after the March 2010 assessment, from February 14 to 22, 2011. 

The assessment team documented security deficiencies in the 

following categories:

Although the assessment team did observe several security

deficiencies, including

the airport's security posture had improved from the March 

3

 Foreign Airport Assessment Reports document information gathered during Global Compliance assessments

of international airports. The reports contain an overview of assessment findings, operational information, and

recommendations for mitigating security deficiencies.

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2010 assessment. 

 The assessment team

identified only one critical SARP deficiency, which improved PAP's 

overall vulnerability rating. After that assessment, OGS conducted 

ASSIST Training in Port-au-Prince. From April 24 to 

28, 2011, ASSIST trainers provided training to 11 

Haitian security screeners. The training was based on ICAO security

standards and focused on

OGS uses the Open SARP Tracking Tool to monitor deficiencies 

noted in the assessment reports. This tool provides a record of any

unresolved or open deficiency noted after it is first reported until it is 

resolved and closed. To further determine whether OGS has taken 

actions to address security concerns, we reviewed Haiti aviation 

security vulnerabilities documented in the Open SARP Tracking Tool. 

We determined that OGS is mitigating security concerns at PAP. As 

of October 19, 2011, either the TSAR for Haiti or the Haitian 

Government began correcting seven of the eight open security items 

listed in the Open SARP Tracking Tool. The open SARP item, which 

did not list specific mitigating actions by either the TSAR or the

government, was the absence of an updated Airport Security Program 

for PAP. However, OGS wrote a corrective action plan to assist Haiti 

in updating the Airport Security Program. 

OGS Has Developed a Long-Term Plan to Assist Haiti in 

Establishing Sustainable Aviation Security Operations 

In addition to providing training and technology to Haitian security

staff to mitigate critical SARPs, OGS has acknowledged the need to 

address broader strategic issues in Haiti's aviation security programs. 

For example, OGS has established a long-term strategy to address the

need to implement a sustainable aviation security framework in Haiti. 

OGS implemented the Haiti Aviation Security Engagement Strategy

and Action Plan on August 1, 2011. The plan aims to enhance TSA's 

efforts to assist the Government of Haiti in building an aviation 

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security framework, at both the national and airport level, which 

provides for more effective aviation security measures to protect

travelers who fly. 

In addition to identifying actions for mitigating specific aviation 

security deficiencies, the plan specifies a comprehensive strategy to 

improve Haitian airport security, which includes multilateral and 

bilateral engagement among stakeholder nations, international 

outreach to include other donor states, technical assistance for national 

and airport security plans, and training courses, and continues needs 

assessment. OGS plans to conduct modified airport assessments and 

air carrier inspections in Haiti to evaluate the effectiveness of its 

efforts.

The plan was scheduled to go into effect during the fourth quarter of 

FY 2010 and remain in effect through FY 2013. However, OGS 

management told us that continued political instability, as well as the

inability of Haiti to maintain security technology and equipment, have

hindered the plan's implementation and OGS's pursuit of long-term 

strategic goals in the country.

TSA Did Not Issue a Timely Emergency Amendment for Haiti 

The author of the letter alleged that security is being compromised because 

OGS is taking too long to draft and release Emergency Amendments (EAs). 

The author claimed that Haiti is just one example of how time-consuming the

EA process is. The author pointed out that an EA should have been drafted

immediately after deficiencies were identified, but OGS took months to draft 

and release an EA. The author did not provide other examples. 

We confirmed that it took TSA several months to issue the EA for Haiti and 

that TSA's internal processes may have contributed to this delay. TSA issued 

the EA for Haiti on November 29, 2010, more than 10 months after the 

earthquake. However, in addition to OGS, several other TSA offices are 

involved in drafting and releasing EAs. Additionally, at the time TSA was 

preparing the Haiti EA, it did not have a Management Directive or Standard

Operating Procedure (SOP) setting forth guidance and timelines for issuing

EAs. 

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Many Offices Have a Role in the EA Process 

TSA uses EAs to revise the security requirements placed on foreign air

carriers in response to a specific incident or to mitigate an imminent 

threat. When an incident occurs-such as the attempted terrorist 

attack on Christmas Day 2009 or the attempted Yemen cargo-based 

attack in October 2010-or an imminent threat arises, TSA evaluates 

whether an EA is needed. As part of this process, OGS (and other 

offices as appropriate) consults with TSA's Office of Intelligence. If it 

decides that the severity of the situation or additional intelligence

justifies an EA, OGS identifies countermeasures that may be required 

to mitigate the situation. All EAs are initially issued with a temporary

status, but they usually have a defined end date. EAs may be

permanently integrated into the baseline security requirements 

contained in TSA's Model Security Program, which foreign air 

carriers must adopt for permission to fly into and out of the United 

States. 

Although OGS has a major role in drafting and issuing EAs, OGS is 

not the only TSA component involved in the process. Because EAs 

must be co-drafted with Security Directives (SDs) issued to U.S. 

carriers, OSO and TSNM share responsibility for creating an EA. 

TSA's Office of Chief Counsel (OCC) provides legal guidance and 

opinion on the nature and scope of the actions under consideration. 

Depending on the issue being addressed, other DHS components and 

other federal agencies may also be involved in the process. Some EAs 

might require a final review by the White House National Security

Strategy Office. At a minimum, once TSA issues an EA, the 

Department of State will facilitate distribution of advance copies to the 

embassies. The responsible TSAR will communicate the technicalities 

of the EA to the appropriate officials at the embassy. 

Although TSA should issue EAs promptly, the timeframe from 

drafting to issuance varies by the severity of the incident or

vulnerability. TSA can issue incident-driven EAs quickly. However, 

EAs driven by security deficiencies, such as the situation in Haiti, take 

longer to prepare because they must include recommendations for 

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corrective actions. These recommendations provide a basis of 

comparison once the airports and air carriers are reassessed to 

determine whether the issues have been resolved. 

TSA issues EAs infrequently. TSA issued only 1 EA in 2009, 8 in 

2010, and 13 in 2011. Of these 22 EAs, 3 were canceled, 2 expired 

and were not reissued, and 1 was superseded. Accordingly, there are

only 16 active EAs. TSA has considered whether to issue other EAs. 

However, given the nature of the incident or vulnerability and the 

analysis of the threat, some proposed EAs were canceled during the

review process or when the situation that led to drafting the EA no 

longer existed.

TSA Took at Least 4l Months To Issue the EA for Haiti 

On November 29, 2010, TSA issued an EA for Haiti. This was at least 

41 months after OGS finished drafting the EA and more than 10 

months since the earthquake. The EA stipulated that prior to 

departure, foreign air carriers must perform additional security

measures for flights bound for the United States from airports in Haiti. 

OGS officials agreed that serious delays occurred between drafting

and releasing the Haiti EA. OGS officials could not identify the date

OGS began to draft the EA, nor could they estimate how long it took 

for OGS to complete the initial drafting and review. They provided a 

timeline showing that the draft EA and corresponding draft Security

Directive experienced a lengthy review that involved the OSO

Procedures Division, TSNM, General Aviation, and the OCC between 

July 15 and November 24, 2010, when Administrator Pistole signed

the final EA. At the time that TSA was preparing the Haiti EA, there

was no established Management Directive or SOP concerning the 

issuance of EAs. According to OGS management officials, this fact 

contributed to the amount of time it took to issue the Haiti EA.

TSA Has Established a New EA Process 

On July 22, 2011, TSA implemented the Risk/Incident-Driven Policy

Review (RIPR) process and assigned its oversight and responsibility to 

OSO. RIPR establishes procedures for assessing requests for and 

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developing EAs, SDs, or other policies. It mandates that the TSA 

Administrator, Deputy Administrator, or the Assistant Administrator

of OSO is responsible for determining when a RIPR working group 

will review an issue and for assigning a RIPR team lead. 

The team lead of RIPR is usually the Deputy Assistant Administrator

of OSO, OGS, or TSNM, and is authorized under the SOP to complete 

a problem statement of the event that initiated the working group. The 

team lead works with the Assistant Administrators to discuss and 

select the team members.

In developing the policy, EA, or SD to implement, the RIPR working

group determines what countermeasure will be implemented to 

mitigate the threat and provides its recommendations to the Senior 

Leadership Team of TSA. Upon review and approval by the Senior 

Leadership Team, the RIPR working group finalizes the documents 

and distributes them to their respective Assistant Administrators. 

Once the Assistant Administrators approve the package, all internal

and external stakeholders are briefed on the specific actions to be

implemented. OGS management officials are optimistic that the new 

process will significantly reduce the amount of time needed to issue 

future EAs. 

Although the RIPR process was only implemented in July 2011, TSA 

has since changed the process through the issuance of a Management

Directive. TSA Management Directive No. 2100.5, which covers all 

security program amendments, including EAs, was signed by the TSA 

Administrator in March 2012. It includes several new contributors to 

the EA creation, review, and approval process. These contributors 

include the Office of Security Operations, Office of Chief Counsel, 

Office of Intelligence and Analysis, Office of Security Capabilities, 

Office of Law Enforcement/Federal Air Marshal Service, and Office

of Policy Coordination and Intergovernmental Affairs. The directive 

assigns primary oversight to the Office of Security Policy and Industry

Engagement (formerly known as TSNM), and secondary oversight to 

OGS. However, the directive does not establish timeframes within 

which each office must complete its actions with regard to the EA 

drafting process. 

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Recommendation 

We recommend that the TSA Administrator:

Recommendation #1: Establish and implement timeframes for

issuing Emergency Amendments, including deadlines for TSA offices 

involved in reviewing and providing comments on them. 

Management Comments and OIG Analysis 

Management Comments to Recommendation #1

TSA concurred with the recommendation. In its response, TSA 

indicated that it has realigned its RIPR process in order to solidify

responsibility for policy, including the development of SDs and EAs, 

within the newly created Office of Security Policy and Industry

Engagement (OSPIE). Additionally, TSA stated that the new process 

is codified in Management Directive 2100.5, which was issued by the 

TSA Administrator on March 15, 2012. Finally, TSA advised that the 

new directive will be further supported by a standard operating

procedure that will specify timelines, roles, and responsibilities.

OIG Analysis

We concur with TSA's response. In its action plan, TSA should 

provide a copy of the standard operating procedure developed to 

support Management Directive 2100.5. We will close this 

recommendation pending review and concurrence with this document. 

This recommendation is Resolved - Open.

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TSA Has Not Evaluated Passenger Screening Procedures at 

All Preclearance Airports

DHS operates customs preclearance services at 14 international airports. Title 

19 USC 1629 grants the Secretary, when authorized by treaty or executive 

agreement, the authority to station customs officers at foreign locations to 

examine people, cargo, and merchandise prior to their or its arrival in the

United States. 

Customs and Border Protection (CBP) has primary responsibility for 

preclearance operations. At designated preclearance airports, CBP inspectors 

use customs procedures comparable to those conducted at U.S. ports of entry

to clear passengers and their belongings for entry into the United States. 

TSA, through its Preclearance Aviation Security Operations Program, is 

responsible for assessing the host airport's passenger checkpoint screening to 

determine whether the foreign airport's screening procedures are comparable 

to aviation security standards for U.S. airports. 

TSA conducts comparability observations, or evaluations, of preclearance 

airports and documents results in preclearance evaluation reports. 

Observation teams led by an IPS manager from the OGS Technical Assistance 

Group conduct the preclearance comparability observations. In addition to 

IPS staff, comparability observation teams often include the TSAR who is 

responsible for the preclearance airport and a TSA expert in domestic 

screening procedures. 

For preclearance comparability observations, TSA teams evaluate the 

airport's passenger security screening procedures and the implementation of 

passenger checkpoint screening measures to assess comparability with U.S. 

standards for domestic screening. Teams analyze passenger, crew, and 

property screening; screening equipment; checkpoint design; and screener 

training and supervision to determine whether the airport is comparable to 

U.S. standards based on its observations. 

DHS preclearance services allow passengers who undergo CBP inspection 

and checkpoint screening at preclearance airports to deplane into the sterile 

area of a U.S. airport and continue domestic travel without undergoing further 

CBP or TSA screening. However, TSA still screens checked baggage from

Review of Allegations of Misconduct and Mismanagement Within TSA's Office of Global Strategies 

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preclearance locations at the U.S. port of entry. Preclearance airports are 

located in Canada, Ireland, and the Caribbean and account for 16 percent of

all international inbound traffic to the United States. 

OGS Has Never Assessed Some Preclearance Locations and, Until

Recently, Did Not Have Written Guidance for Their Evaluation

The author of the letter alleged that OGS has been "very slow� in 

addressing deficiencies at preclearance airports. The author did not 

identify or explain the deficiencies. 

We validated the author's allegation. 

 

The evaluation process was slow for two reasons. First, memorandums 

of cooperation between TSA and host governments recognizing

preclearance operations and cooperative efforts to enhance security

screening do not exist for all 14 preclearance locations. 

OGS management

officials advised us that efforts are underway to establish these 

agreements, but could not tell us when these actions would be 

completed. 

Second, although OGS has been responsible for the preclearance 

program since late 2007, headquarters was not managing the program 

until the program transferred to IPS in 2010. Instead, individual 

TSARs managed the preclearance process at airports within their areas

of operation. During this time, TSA did not have standard processes 

and procedures for conducting comparability observations, or a 

schedule for executing the assessments. Without established operating

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procedures, a policy to define comparable security screening did not 

exist. As a result, it is possible that TSA used inconsistent evaluation 

standards and metrics to determine whether screening procedures at 

preclearance locations are comparable to U.S. standards.

However, OGS has made programmatic changes bringing greater 

focus to the program. In December 2010, IPS assumed responsibility

for the program. Since then, OGS has taken several steps to 

strengthen the program, including reinitiating preclearance

comparability assessments and establishing an SOP. Table 1 shows 

the dates of the most recent assessments and the schedule for 

upcoming assessments. 

To standardize the program, OGS issued an Operations Directive that 

provides a foundation for the program and delineates a four phase 

process for evaluating Preclearance Aviation Security Operations 

Program locations. Under the directive, OGS will conduct 

preclearance comparability evaluations visits annually. The process 

includes a baseline visit to assess comparability to domestic screening

standards, followed by period of remediation in which security gaps

are resolved. Should remediation of a security concern be required, an 

airport will be reevaluated to determine the status of any comparability

gap. The operations directive further clarifies the roles and 

responsibilities of TSA program offices outside of OGS that are 

involved in the Preclearance Aviation Security Operations Program. 

OCC is responsible for negotiating memorandums of cooperation for 

each preclearance location, including any technical annexes, while 

OSO assists in the development of evaluation criteria, training

activities, and preclearance evaluations. 

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Table 1: Preclearance Locations, Most Recent Evaluation, and 

Next Scheduled Evaluation

Most Next 

Airport Airport Recent Scheduled

Country Code Name City Evaluation Evaluation

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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In addition to the operational directive, OGS drafted a comprehensive 

SOP which provides specific operational steps and guidance for

administering the Preclearance Aviation Security Operations Program. 

The document includes program goals and objectives, defined roles 

and responsibilities, a description of the program's process and 

procedures for conducting comparability assessments, and strategies 

for mitigating security risks. In developing this document, OGS has 

conducted several site visits to test and assess the SOP's methodology. 

In November 2011, OGS began piloting a new reporting format and 

scoring system for Preclearance evaluation reports. The results of the 

evaluation, a comparability score, and recommended corrective 

actions for any identified gaps will be presented in a Preclearance 

Observation Summary Report. Evaluation teams document their 

observations of 41 screening categories in a detailed Preclearance 

Comparability Analysis. Preclearance airports must attain a

Preclearance Comparability Analysis score that meets or exceeds a

certain threshold to achieve comparable status. 

Recommendation 

We recommend that the TSA Administrator:

Recommendation #2: Require rescreening of all passengers arriving

at U.S. ports of entry from preclearance airports that fail to achieve 

comparable status.

Management Comments and OIG Analysis 

Management Comments to Recommendation #2

TSA concurred with the recommendation. In its response, TSA stated 

that the preclearance program established within OGS will provide

ongoing evaluation of the security operations at preclearance airports

to ensure that they are comparable with U.S. standards. Where these

procedures are found to be deficient, TSA will work with the 

appropriate authorities to achieve comparability so that operations may

continue and that passengers arriving in the United States from 

preclearance airports can seamlessly transfer to flights.

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OIG Analysis

Although TSA indicated concurrence with the recommendation, its 

response indicates only partial concurrence. TSA stated that in cases 

where a preclearance airport has significant areas of noncomparability

or where the risk is too great, TSA may require the rescreening of 

passengers and property arriving in the United States from that 

location until such time as the appropriate authority implements 

adequate security measures to ensure comparability with U.S. 

standards. TSA explained that it has several options available to 

address preclearance flights from locations where deficiencies exist. 

In addition to rescreening passengers and baggage, other options 

include issuance of a location specific SD and/or EA, and/or a 

reevaluation of the preclearance program at that location. While we 

appreciate that TSA has other options available to it, we believe that 

TSA should issue guidance that makes it clear that, at a minimum, 

passengers and property arriving from any preclearance airport that

does not maintain comparability with U.S. standards will be 

rescreened. We will close this recommendation pending receipt and 

review of this guidance. 

This recommendation is Resolved - Open

Creation of the Regional Director Position Raised Concerns 

The author of the letter alleged that the creation of the regional director 

position added an unnecessary layer of bureaucracy and is a waste of 

government funds. The author asserted that the TSARs are K-band 

employees who should not require close supervision by a regional director 

and should be able to work effectively with foreign governments without the 

presence of a regional director. The author alleged that the costs of sending

the regional directors and their families overseas, overseas education for their 

children, and acquiring overseas real estate were a waste of government

funds. One of the positions was in Frankfurt, Germany, and the other was in 

the Republic of Singapore. 

OGS provided ample justification for creating the positions, which were 

vetted by TSA's Executive Resources Council. The Executive Resources 

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Council provides guidance and recommendations to the Deputy Administrator 

and Administrator regarding recruitment and selection of individuals at the 

senior-executive level. Because we determined that there was ample 

justification for creating the positions, we were less concerned with the costs

involved in their deployment. The costs incurred are the same as would be 

expected for any overseas assignment of OGS personnel. 

OGS management's communication regarding the roles and responsibilities of 

the position, as well as other actions, were legitimate reasons for the author

and others to question the need for the positions and whether OGS might have 

created these positions for the individuals now occupying them. Further, 

OGS management provided conflicting descriptions of the regional director's

roles and responsibilities and did not implement the position as originally

approved by the Executive Resources Council. However, OGS did not 

circumvent the hiring process or take improper actions to select either the 

Frankfurt or Singapore regional directors. 

The allegation called attention to an area of ongoing tension within OGS. 

Management believes that executive-level experience is required to represent

TSA's interests when dealing with foreign governments or a crisis, but 

support for this approach is not unanimous within OGS. The decision to 

create and deploy regional directors caused mixed reactions by OGS staff. 

We spoke with 29 K-band employees about the new regional director 

positions. K-band employees in OGS tend to be Regional Managers located

at TSA headquarters, Regional Operations Center Managers, and TSARs. 

They are the employees who are most likely to have direct interaction with the

regional directors. Fourteen K-band employees said that they either support 

the establishment of regional director positions or believe that the position has 

the potential to enhance OGS operations. Two employees supported the 

establishment of a regional director in Europe, but felt that individual 

directors were not necessary for other regions. 

Eight employees did not support the new position. They gave a variety of

reasons. For example, one employee questioned the need for a field executive 

to direct TSA operations during crisis situations, explaining that incidents of a 

scale requiring crisis response occur infrequently. Another employee believed 

that the implementation of regional directors duplicates efforts already

undertaken by TSARs, and three TSARs believed that the money to fund the 

regional director position would be better spent on hiring additional inspectors 

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or support staff at lower pay bands. Five K-band employees offered no 

opinion concerning the positions.

Some of the 29 K-band staff cited a need for better communication from OGS 

management about justifying, establishing, and deploying new regional 

directors. Eight K-band employees said they understood the role of the

regional director and how the position fit into the OGS organizational 

structure. Eight others said they did not clearly understand the role and 

responsibilities of the regional director and how the new directors fit into the 

OGS organizational structure, with three of these employees saying they were

unclear about how the reporting structure would change. 

OGS's Justification for the Regional Director Position

Regional directors are executives who oversee international field 

operations and manage interagency relationships to mitigate

international transportation security vulnerabilities. OGS created the 

position to provide TSA with executive-level representation for the 

Assistant Administrator in meetings and negotiations with foreign

governments. TSA initially authorized the international deployment 

of two regional directors in December 2010. 

First, regional directors serve as advisors and experts to foreign

officials to consult on security procedures, share best practices, and 

identify common policies to minimize duplication of effort. Second, 

they are charged with integrating and unifying the efforts of the 

various OGS operational directorates. OGS management officials 

described this as the ability to cut across directorate lines in order to 

advance a more consistent international strategy. Third, they will lead 

OGS efforts during a crisis and incident response situations within 

their area of operation. Because of time differences between TSA 

headquarters and the various international locations where TSA 

operates, regional directors have a great deal of autonomy and are 

expected to exercise independent judgment while making timesensitive decisions for the agency.

OGS originally requested approval of four regional director positions 

to cover Asia/Pacific, Europe, Western Hemisphere, and Africa/Middle 

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.� 

 

 

 

 

East. The Executive Resources Council authorized only the 

Asia/Pacific (Singapore) and Europe (Frankfurt) positions. 

OGS Management Has Provided Conflicting Descriptions of the

Regional Director's Roles and Responsibilities

Contributing to the uncertainty of the need for new regional director 

positions were the conflicting descriptions that OGS management 

provided with regard to their roles and responsibilities. 

On December 22, 2010, the OGS Assistant Administrator presented a 

request to the Executive Resources Council for two regional director 

positions. The Executive Resources Council approved regional 

director positions for Asia/Pacific and Europe, and directed OGS to 

advertise the positions and evaluate funding for them. 

The approved December 2010 Executive Resources Council package 

states that regional directors will oversee all tactical operations within 

their area of responsibility and have direct supervisory authority over 

TSARs and Regional Managers. The package further states that

"reporting directly to the Director of IO, the regional director will 

receive guidance on outreach and engagement priorities for TSA and 

OGS that will then be implemented directly with high level

government counterparts in the field

However, a March 8, 2011, action memorandum from the OGS 

Assistant Administrator to Administrator Pistole describes the regional 

director position differently. The action memo, which requested 

approval to forward a National Security Decision Directive (NSDD)-

38 request to the DHS Office of International Affairs, stated that 

regional directors are responsible for oversight of each Regional

Operations Center, TSAR, and IIR within their area of responsibility.4

The request did not describe the regional director's supervisory

authority over TSARs and Regional Managers, as the Executive 

Resources Council package did. The same oversight description is 

written in a subsequent undated action memo from Administrator 

4 NSDD-38 gives the Chief of Mission control of the size, composition, and mandate of overseas full-time

mission staffing for all U.S. Government agencies. An NSDD-38 request is required to initiate DHS staffing 

changes at overseas diplomatic posts. 

Review of Allegations of Misconduct and Mismanagement Within TSA's Office of Global Strategies 

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Pistole to DHS Deputy Secretary Jane Lute requesting that DHS

initiate the NSDD-38 process. 

Then, in a March 15, 2011, action memorandum from the Assistant 

Secretary for Policy to Secretary Janet Napolitano, the regional

director position is described differently again. The memorandum 

requests authorization for the Office of Policy to initiate the formal 

NSDD-38 process with the Department of State, thus allowing TSA to 

post Senior Executive Service-level regional directors in Singapore 

and Frankfurt. Similar to the preceding action memos, the document 

states that the regional directors will be responsible for oversight of 

each Regional Operations Center, the TSAR, and the IIR within their 

area of responsibility, but does not mention supervisory responsibilities 

over TSARs. However, this action memo states that the regional 

director "would be the supervisor of all TSA personnel at post,� 

meaning "nine staff in Singapore and 33 staff in Frankfurt.� This 

description of the regional director position is different from all the

previous documents. On March 30, 2011, Secretary Napolitano 

approved the request for action. 

Finally, TSA's formal NSDD-38 applications for Singapore and 

Frankfurt, which were approved by the Department of State, says in 

the "Justification for Requested Position� section that regional 

directors will be responsible for administrative and technical oversight 

of each Regional Operations Center, TSAR, and IIR in their respective 

areas of responsibility. The request does not call for supervisory

authority over OGS employees, as had previously been approved by

the Secretary of DHS. 

The regional director position has not been implemented as originally

approved by the Executive Resources Council. Regional directors 

have no supervisory responsibilities over OGS employees. When 

OGS leaders announced the regional director position, they explained 

that the reporting structure for staff in GC and IO would not change. 

TSARs, Regional Managers, and the IO Director have maintained 

their reporting relationship, although TSARs and Regional Managers 

have been instructed to coordinate their efforts and share pertinent 

information with the regional director so they can continue to 

implement TSA's strategic direction within their region. Furthermore,

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the Singapore and Frankfurt regional directors do not report to the 

Director of IO as approved by the Executive Resources Council. 

Instead, the regional director position reports directly to the Assistant 

Administrator. The Singapore regional director told us that while he

partners with the Director for IO, he has always operated under the 

assumption that he would report directly to the Assistant Administrator. 

The Singapore regional director added that the original justification for 

the regional director position offered two possible reporting structures. 

However, these documents did not mention alternate reporting

structures in the justification package approved by the Executive 

Resources Council.

The Selection of One Regional Director Led to Perceptions That 

OGS Created the Position for Him

Prior to the Executive Resources Council's approval of the current 

regional director positions, OGS had proposed to the council a new 

TSA Senior Executive Service position called an International 

Transportation Security Executive to be based in Sydney, Australia. 

On April 1, 2010, OGS asked the Executive Resources Council 

whether it could create this position and sought approval for a specific 

candidate to fill it. The Executive Resources Council postponed a 

decision pending further discussion. We could find no record that the 

establishment of this position received any further consideration. 

However, the fact that OGS had considered a candidate for placement

in an international OGS position before the position existed raised 

legitimate concerns. We spoke with 46 OGS employees who said they

were aware of instances where they believed a position was created for 

a particular individual. Nine employees specifically cited the creation 

of the regional director as an example. 

The manner in which OGS selected the former OGS Deputy Assistant

Administrator for the Singapore regional director position was not 

improper. He applied for the position through a vacancy announcement 

posted on USAJobs and was ultimately determined to be the best

qualified candidate. The Executive Resources Council reviewed and 

approved his selection at its April 14, 2011 meeting. 

Review of Allegations of Misconduct and Mismanagement Within TSA's Office of Global Strategies 

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y� 

 

 

We found nothing improper in the selection of the former Assistant 

Administrator of OSO for the regional director position in Frankfurt. 

The Executive Resources Council also approved his selection at its 

April 14, 2011, meeting.

TSAR Positions Are Properly Placed

The author of the letter alleged that the random placement of TSAR positions 

has resulted in waste and inefficiency. The author suggested that OGS has too 

many (three) TSARs in the Caribbean because it is not a high threat level 

area, and too many in Europe because the current OGS leadership is very

Eurocentric. The author believes that OGS should spend more "energ

working with developing countries. Several employees also expressed to us 

their concerns about how OGS selects TSARs, their qualifications, and, in 

some cases, where they are located.

Based on our review of TSAR positions in the Caribbean and Europe, and 

their areas of responsibility, we determined that management's rationale for 

placing TSARs globally is sound. 

Overview of the TSAR Position

The current TSAR position came out of a program established by the 

Federal Aviation Administration as a result of the Aviation Security 

Improvement Act of 1990 (P.L. 101-604), which mandated that the 

Federal Aviation Administration take initiatives to enhance 

international aviation security. As a result, Civil Aviation Security

Liaison Officers were created and posted at 20 different locations 

overseas. The first one was deployed to the American Embassy in 

London and was involved in ICAO conferences and assisted with 

furthering U.S. security initiatives with the United Kingdom's airports 

and air carriers. This initial engagement with foreign aviation security

officials served as a significant precedent for future initiatives between 

the United States and partnering governments.

The current TSARs are K-band employees who rely on their

knowledge and experiences in diplomacy and aviation security to 

negotiate with foreign countries. They help TSA and DHS carry out 

Review of Allegations of Misconduct and Mismanagement Within TSA's Office of Global Strategies 

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critical U.S. initiatives regarding aviation security. TSARs work to 

advance TSA objectives overseas, while enhancing partnerships with 

foreign governments. They must be politically savvy and able to 

negotiate with high-level foreign government officials, develop and 

maintain partnerships in the aviation security community, and provide 

quick resolutions in crisis situations. The TSAR serves as the

coordinator for TSA and DHS teams regarding transportation-related 

security incidents that involve U.S. interests. Within each area of

responsibility, the TSAR must also develop engagement strategies for

the countries, as well as prepare budgetary requests to fund program 

requirements. 

TSARs Are Selected Based on a Standardized Process That 

Includes TSA Senior Management

OGS considers many different factors when deciding whether a 

candidate is qualified to be a TSAR. Prospective candidates must 

have knowledge of international transportation security standards, 3 to 

5 years of TSA and international experience, as well as 1 year of

specialized experience at the J-band level. TSARs are deployed to 

countries with various economic and cultural standards, so it is also 

important for prospective TSARs to be open and understanding of the 

diverse cultures that may be present in the area of responsibility to 

which they are assigned. Finally, the TSAR must be able to 

communicate diplomatically, both orally and in writing, and to 

maintain poise in stressful situations. 

Once OGS determines that a prospective TSAR is qualified, the 

candidate undergoes a rigorous interview and testing process. The 

process begins with a selection panel consisting of the Regional 

Managers within IO, who review resumes and extend invitations to top 

candidates for interviews. The candidates must also complete an essay

question within 25 minutes, and the scores from the interview and 

writing sample are combined for the candidate's final ranking. These 

scores are provided to the IO Director along with the panel's 

recommendations. The IO Director identifies and recommends the 

candidate to the Deputy Assistant Administrator and Assistant 

Administrator. Upon their review and approval, the Executive 

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Resources Council approves the selection of a candidate. OGS then 

extends a formal offer to the candidate.

Our review of the background and qualifications of the current TSARs 

indicated that they appear to be well-qualified for their positions. 

Most of the current TSARs have significant overseas experience. 

Additionally, most have significant prior work experience in either 

TSA components such as Federal Air Marshal Service, OCC, or OSO, 

or other federal agencies such as the Federal Aviation Administration, 

National Aeronautics and Space Administration, or the Office of 

Personnel Management. Several TSARs also have aviation security

and law enforcement backgrounds. All of the TSARs underwent the 

aforementioned selection process and were approved by the Executive 

Resources Council. We found no evidence that OGS selected any

TSARs solely on the basis of their prior acquaintance with the former 

Deputy Assistant Administrator or Assistant Administrator. 

TSARs Are Deployed Throughout the World

TSA deploys TSARs worldwide. With the exception of three TSARs 

who are co-located at the Miami Regional Operations Center, TSARs 

are stationed at diplomatic posts and are considered a part of the 

diplomatic staff of the embassy to which they are assigned. TSARs 

are assigned a geographic area of responsibility that usually includes 

several countries. Appendix D provides the current TSAR locations 

and their areas of responsibility.

OGS periodically reviews every area of responsibility to ensure that

the workload of each TSAR is balanced with that of other TSARs in 

the region. Among the factors that can cause a change to a TSAR's 

area of responsibility is a change in the volume of U.S.-bound flights 

from countries within that area or a decision to create a new TSAR 

position. For example, OGS might add Turkey to TSAR Madrid's 

area of responsibility because it is an emerging market that requires 

additional attention. In fact, the IO Director told us that OGS is 

currently considering a realignment of all TSARs in Europe. OGS is 

also considering the creation of a TSAR position in India because of 

U.S. plans to engage the Indian Government. Other factors that might 

lead OGS to realign areas of responsibility include a specific TSAR's 

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unique language skills or cultural ties that may be more relevant to one

country than another. 

While we were conducting our fieldwork, OGS requested the approval 

of a new TSAR position that would have responsibility for Oceania. 

We reviewed OGS' analysis of the need for the position, the 

justification it provided to the Executive Resources Council with 

regard to the position, and the council's subsequent approval of the 

position and the candidate. We found no discrepancies or causes for 

concern. The actual deployment of the TSAR Oceania position is on 

hold pending the availability of funding. 

OGS Is Reviewing TSARs Deployed to the Caribbean 

The author alleged that having three TSARs for the Caribbean is 

wasteful and inefficient because the Caribbean is not a high-level 

threat area.

Presently, TSAR Nassau, TSAR Caribbean North, and TSAR 

Caribbean South are responsible for liaising with foreign governments 

in the Caribbean region. Additionally, TSAR Central America is 

responsible for one Caribbean country, the Dominican Republic. 

Among these TSARs, TSAR Nassau is responsible for eight countries 

with 22 last points of departure airports to the United States, while 

TSAR Caribbean South is responsible for 10 countries with 13 last 

points of departure airports.5

 TSAR Caribbean North handles 12 

countries with eight last points of departure airports, and the 

Dominican Republic has five last points of departure airports. 

OGS is considering realigning the Caribbean areas of responsibility

again and deploying only two TSARs to the region, as in the past. The 

IO Director told us that prior to October 2010, only two TSARs had 

been responsible for the Caribbean region. When OGS determined 

that there was too much work for them, OGS realigned the area of 

responsibility and added another TSAR. Since deploying the third 

TSAR, it has become increasingly apparent that dividing the 

5

 Last points of departure airports are overseas airports from which U.S. and foreign air carriers operate flights 

directly into the United States.

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Caribbean into three areas of responsibility may have been illconceived because some of the TSARs are underutilized. OGS 

continues to review workloads and may consider adjustments as 

warranted. 

Appendix D shows the current areas of responsibility for the three 

Caribbean TSARs and TSAR Central America. 

The Effectiveness of Capacity Development Programs Is Difficult To 

Measure 

The author of the letter wrote that OGS' Capacity Development efforts are 

ineffective and wasteful, particularly because of programs like ASSIST. 

ASSIST was created to help developing countries enhance their aviation 

security capacity and effectively build sustainable long-term programs. The

plan was to work with local alliances to conduct assessments, develop 

aviation security programs and procedures, and share best practices with 

neighboring countries. The author alleged that thousands of dollars have been 

spent on the program, which has done very little other than offer basic 

screener training. 

We were not able to substantiate this allegation, mostly because it is very

difficult to quantify the effectiveness of the training that OGS provides. 

OGS's Capacity Development Branch Provides Training on a 

Variety of Technical Subjects

In 2007, OGS established the CDB from elements of the former 

international training component of the OSO's Security Enforcement 

Training Academy. CDB's task is to develop competencies in global 

aviation security standards and practices among security staff from

international partner organizations. CDB carries out training not only

for TSA, but also in partnership with ICAO, the Department of State's 

Anti-Terrorism Assistance Program, the Organization of American 

States, and the Department of Transportation's Safe Skies for Africa 

Program. 

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In addition to individual training missions and assignments, CDB

manages the ASSIST program. ASSIST, established in FY 2009, 

conducts structured, long-term aviation security development 

assistance for countries that have failed to meet international aviation 

security standards set by ICAO. The program's goal is to enable 

nations to maintain sustained aviation security capabilities by

conducting needs assessments, executing training programs, and 

developing sustainment practices. ASSIST engagements generally last

12 to 18 months.

OGS spent $798,016 on capacity development programs between 

FY 2009 and FY 2011 (see table 2). 

Table 2: OGS Funding for Capacity Development

Fiscal Year Total Amount Spent

2009 $388,777 

2010 $243,646 

2011 $165,593 

Total $798,016 

A number of external organizations, including the Organization of 

American States and Safe Skies for Africa, provide financial 

assistance to help cover travel and per diem expenses. For example, 

the Organization of American States provided $83,677 in FY 2010 and 

$102,470 in FY 2011, and has committed to provide funds for 

FY 2012. Safe Skies for Africa has committed $1.2 million in 

FY 2012 and FY 2013 for regional training in Safe Skies countries. 

However, the implementation plan for these funds is still being

developed. Because they are providing funding, external 

organizations have a great deal of influence on what training is 

provided and to what countries it is provided. 

Although the anonymous author correctly pointed out that CDB has 

spent thousands of dollars on this program, the author's assertion that 

capacity development programs provide little more than basic screener 

training is inaccurate. CDB coordinates with TSARs, foreign

counterparts, and international organizations to identify security

development opportunities and implement training programs. CDB

instructors, along with subject matter experts from other TSA offices, 

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conduct training sessions on a variety of technical subjects, including

inspector skills, screening techniques, quality control, incident 

management, security instructor skills, and the development of 

national programs. 

The distribution of funds for countries receiving capacity development

assistance is determined by analyzing the number of last points of 

departure, annual flight volume to the United States, threat and 

vulnerability ratings, and training requests made by TSARs and host 

countries. After evaluating the different factors and determining a

final rating, CDB prioritizes the locations and determines what 

percentage of its funds will be used to address security vulnerabilities in

each country. Although CDB also aims to train underdeveloped 

countries to increase their security posture, these countries do not have 

a large volume of passengers traveling to the United States. 

Perceptions of Discrimination, Favoritism, and the Abuse of Power 

Do Exist

The author of the letter alleged that the perception in OGS is that the Assistant 

Administrator favors young and attractive females and discriminates against 

older employees, especially women and minorities. The author provided no 

details concerning specific instances of discrimination. The author alleged 

that OGS gives the majority of awards and promotions to younger employees 

and those who work in the front office, adding that this applies to training and 

travel opportunities as well. The author did not provide specific examples. 

Additionally, the author asserted that favoritism is most apparent in OGS's 

hiring practices, and that there is no fairness or transparency. The author 

asserted that the best qualification anyone could have when wanting to work 

for OGS was to be a friend of the Assistant Administrator or the former 

Deputy Assistant Administrator. Finally, the author claimed that abuse of 

power in OGS is egregious and that OGS leadership manages through fear 

and intimidation.

While we could not substantiate the allegations, there is a perception among

some OGS employees that some or all of these issues exist. Several

employees said that they had personally experienced some of these issues or 

knew of someone who had. 

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Discrimination, Retaliation, and Favoritism

Discrimination and retaliation are commonly used terms that involve

complex areas of law. Each requires specific elements of evidence to 

meet its legal threshold. Federal employees and job applicants are 

protected against discrimination in employment on the basis of race, 

color, religion, sex (including pregnancy), sexual orientation, national 

origin, age (40 or older), or disability. In addition, federal employers 

are required to provide a reasonable accommodation for individuals 

with disabilities and for religious purposes. 

Employees are protected against retaliation for two categories of

activities: whistleblowing and exercising their right to engage in 

certain protected activities. The whistleblower category protects

employees, former employees, and applicants for employment against 

reprisal for lawfully disclosing information they reasonably believe is 

evidence of a violation of a law, rule, or regulation in the workplace or

by federal employees. It also protects against reprisal for disclosing

gross mismanagement, gross waste of funds, abuse of authority, or 

substantial or specific danger to public health and safety. The second 

category protects employees from reprisal for exercising their right to 

engage in certain protected activities, including the following:

•	 Filing an appeal, complaint, or grievance;

•	 Testifying for or assisting another in exercising such a right; 

•	 Cooperating with or disclosing information to the Special 

Counsel or to an Inspector General; or

•	 Refusing to obey an order that would require the individual to 

violate the law.

Sometimes employees believe that supervisors have discriminated or 

retaliated against them by giving preferential treatment to other 

employees based on biases or personal relationships. Although an act 

of favoritism is not the same as discrimination or retaliation, 

employees are protected against favoritism, and employment decisions 

must be based on objective factors. However, favoritism can be 

difficult to identify because of insufficient evidence. An employee 

might interpret as favoritism what in reality could be fair, merit-based

Review of Allegations of Misconduct and Mismanagement Within TSA's Office of Global Strategies 

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behavior by a supervisor in a given instance. For example, 

differentiating among employees based strictly on performance would 

not be favoritism. Employees enter into positions with different skills 

and prior work experience and may be given assignments of differing

complexities. One employee might have the expertise to complete an

assignment with minimal guidance from a supervisor, whereas another 

employee might need more coaching or supervision. It would not be 

favoritism to treat employees differently under these circumstances; 

rather, it would be good management. However, if a supervisor gave 

an assignment to one employee over another because of a personal 

friendship with that employee, rather than basing the assignment on 

legitimate business factors such as expertise, workload, or 

performance, that could be favoritism. 

Discrimination and Inequitable Treatment

We could not confirm that the Assistant Administrator favors young

and attractive females and discriminates against older employees, 

particularly women and minorities. However, 18 of 144 employees 

interviewed, or 13 percent, felt directly discriminated against. Of the

18 employees, 1 said that the discrimination was based on race; 2 said 

that it was based on their prior employment; and 5 said that they had 

been discriminated against when they were not given proper 

consideration for in-position increases, promotions, or selection to 

positions for which they had applied. The remaining employees chose 

not to provide additional explanation. 

A similar number of employees reported that they were aware of acts 

of discrimination or inequitable treatment. Approximately 20 

employees interviewed, or 14 percent, indicated that they were aware 

of various instances of discrimination or inequitable treatment. 

Among these 20 employees, 4 believed that promotions and selections 

to positions were handled in a discriminatory manner. 

We reviewed demographic data for OGS. The percentage of females 

has grown 11 percent since 2009; from 29 percent in 2009, to 36 

percent in 2010, and to 40 percent in 2011. On the surface, these data 

appear to support the author's claim. However, our review supported 

the following assessments: 

Review of Allegations of Misconduct and Mismanagement Within TSA's Office of Global Strategies 

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•	 We did not identify any anomalies in the hiring process that 

would have indicated a preference for hiring younger 

employees or females;

•	 The administration of awards, promotions and in-position 

increases, and training did not appear to favor younger

employees or females;

•	 There were no determinations made against the agency

concerning the hiring of younger employees or females; and

•	 Our comparison of OGS demographics to that of TSA indicated 

that the average age of OGS employees is still well above the 

average age of TSA employees. The percentage of females in 

TSA has remained around 37 percent during the same period, 

which is consistent with the percentages of females employed

in OGS.

Awards, Promotions and In-Position Increases, Training, and

Hiring 

The author of the letter also alleged that OGS gives awards and 

promotions to younger employees and those who work in the front

office. The author alleged that favoritism toward young and female 

staff is a major factor in the selection of employees for training

opportunities. For example, some employees are approved for training

that costs up to $10,000, while other employees struggle getting

approval for courses that cost $500. Finally, the author alleged that 

favoritism is particularly prevalent in OGS' hiring practices, and 

asserted that OGS chose individuals for positions who did not apply

formally because they knew the Assistant Administrator or Deputy

Assistant Administrator. Several employees also perceive that 

favoritism exists in awards, promotions and in-position increases, 

training, and hiring. 

We did not identify any obvious discrepancies or evidence of 

favoritism regarding OGS' administration of awards, promotions and 

in-position increases, training, or hiring processes. The results of our 

Review of Allegations of Misconduct and Mismanagement Within TSA's Office of Global Strategies 

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review were consistent with those of TSA Office of Inspection's 

March 2011 comprehensive review of the same records. 

Awards

Awards such as certificates, time off, or cash bonuses are given in 

recognition of an employee's work contributions. Eighty-two or 57 

percent of the 144 employees we interviewed said that they received at 

least one award since joining OGS. Still, some employees felt that 

these awards were not administered equitably. Of the 144 employees, 

14 (10 percent) said that they were aware of employees who, in their 

opinion, received awards that they did not deserve. Of these 

employees, two said that those who work in the front office of OGS 

should not have received awards. Another employee alleged knowing

of TSARs with no aviation backgrounds who received awards, and 

two others said the management team at Regional Operations Centers 

received awards despite not completing their duties. We were not

provided sufficient information to further review these matters. 

OGS gave cash awards to 161 employees in FY 2010 and 155 

employees in FY 2011, and distributed the awards throughout the 

organization (see table 3):

Table 3: Distribution of Cash Awards for FY 2010 and FY 2011.

Location Number of Employees

FY 2010 FY 2011

Headquarters 64 70 

Miami 18 16 

Dallas-Fort Worth 16 17 

Los Angeles 5 4 

Frankfurt 12 15 

Singapore 5 5 

TSAR 22 20 

IIR 8 8 

N/A 11 0 

N/A represents employees who were on temporary detail to OGS from other TSA

offices. This category is unique to the FY 2010 data provided to us by OGS.

Review of Allegations of Misconduct and Mismanagement Within TSA's Office of Global Strategies 

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OGS appeared to administer other types of awards in a similar manner. 

According to the data provided by TSA Office of Human Capital, 

OGS distributed time-off, monetary, and nonmonetary awards 

throughout the organization to all races and genders for fiscal years 

2009, 2010, and 2011 (see table 4). The table accounts for all awards

administered in OGS from FY 2009 through 2011. There is the 

possibility of multiple awards given to the same individuals. 

Table 4: OGS Awards for FYs 2009-2011

Categories FY FY FY

2009 2010 2011 

Gender Male 159 227 134 

Female 87 136 99 

Ethnicity Asian, American Indian, or 

Alaska Native 17 29 18 

Black or African American 39 48 36 

Hispanic/Latino 44 54 50 

White 146 232 129 

Average Age 46.6 45.9 44.0 

Total Number of Awards 246 363 233 

Promotions and In-Position Increases 

An in-position increase is a raise to an employee's basic pay rate, with 

no change in position or pay band. OGS awards in-position increases 

to its top-performing employees. With regard to whether OGS 

management exhibited favoritism in promotions or in-position 

increases, 61 out of 144 employees interviewed, or 42 percent, 

indicated that they have received either a promotion or an in-position 

increase since joining OGS. 

Twenty-one employees (15 percent) said that employees received 

promotions that, in their opinion, were not justified. Of those 21 

employees, 5 said that OGS was promoting unqualified individuals. 

One employee said that an employee's resume was altered after 

submitting it in order to qualify for a position. Five claimed that OGS 

had not properly selected TSARs and awarded in-position increases to 

TSARs who did not deserve them.

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We analyzed promotions data for OGS for FYs 2009, 2010, and 2011 

(see table 5). Although the data-particularly that for FY 2010-

appeared to indicate some inequity in the promotions, our review of 

the records revealed no indications that particular groups of employees 

were favored.

Table S: OGS Promotions for FYs 2009-2011

Categories FY FY FY

2009 2010 2011 

Gender Male 7 8 9

Female 6 7 2

Ethnicity American Indian or Alaska 

Native 0 0 0 

Asian 2 0 0 

Black or African American 2 0 4 

Hispanic/Latino 2 1 3

White 7 14 4 

Average Age 42.3 41.2 43.3 

Total Number of Promotions 13 15 11 

We also analyzed the in-position increases for FY 2010 and FY 2011. 

OGS awarded increases to 40 employees in FY 2010 and 52 

employees in FY 2011. Like awards, OGS allocated in-position 

increases throughout the organization (see table 6). When granting inposition increases, managers consider performance appraisal scores 

and the date their last increase was awarded. OGS utilized this 

criterion in determining in-position increases for FY 2011. 

Review of Allegations of Misconduct and Mismanagement Within TSA's Office of Global Strategies 

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Table 6: Distribution of In-position Increases for FY 2010 and

FY 2011 

Location Number of Employees

FY 2010 FY 2011

Headquarters 18 23 

Miami 6 7 

Dallas-Fort Worth 3 2

Los Angeles 2 1 

Frankfurt 5 6 

Singapore 1 3 

TSAR 3 9

IIR 2 1 

To determine whether OGS was awarding promotions and in-position 

increases according to the applicable TSA Management Directives, we 

reviewed selected administrative and personnel records. We 

determined that OGS followed procedures, which includes a 

promotion board, with regard to promotions. The promotion board's 

records showed that each applicant was asked standard questions and 

that the applicant's responses were scored. Of the cases we reviewed, 

OGS selected the highest rated applicant. In addition, when personnel 

are promoted to supervisory positions, TSA's Office of Human Capital 

must approve the selection. 

Training

The author alleged that management favors young and attractive 

female staff when selecting employees for training opportunities. The 

author also alleged that while some employees are approved for 

training that costs as much as $10,000, other employees struggle for

permission to attend training courses that cost $500. The author did 

not identify any employees management has allegedly favored when 

approving training, or specific training opportunities that it denied to 

certain individuals. Twenty-five of 144 employees (17 percent) we 

interviewed did not believe that OGS offered training opportunities 

equitably. Of the 25 employees, 5 inspectors said that they did not 

feel that management afforded their Regional Operations Center the 

same training opportunities as other OGS offices. Four employees 

said that OGS management permitted certain employees to attend 

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specialized technical training courses that were not relevant to their

current position and duties. Other employees did not provide 

explanations of their responses. 

Without knowing which OGS employees expressed an interest in 

training but were denied, and for which training, it is difficult to assess 

the extent to which management may have favored individuals when 

approving training. Very few employees have attended training

costing $10,000 (see table 7). In addition, training records do not 

support the allegation that management favors females when 

approving training. However, we learned of situations that might have

provided the basis for the allegation. In one instance, management

approved training for one female and one male employee at a cost of

almost $8,000 each, but the training was canceled and OGS did not 

incur any costs. We also noted that employees in two Regional 

Operations Centers had not attended external training in recent years. 

Finally, 76 percent, or 110, of the 144 employees we interviewed said 

OGS administers training equitably. For these reasons, we did not 

conclude that management was favoring particular employees. 

According to OGS' training records for FYs 2010, 2011, and the first 

quarter of FY 2012, only TSARs have attended training costing

$10,000.6 In FY 2010, nine TSARs attended the mandatory TSAR 

Training Academy at a cost of $9,980 each. In addition, two of these 

TSARs attended security training at the Department of State's Foreign

Service Institute at a cost of $335 each, and one TSAR attended 

language training at a cost of $8,750. In FY 2011, one TSAR attended 

a Foreign Service Institute language training course at a cost of

$8,560. In FY 2010, one OGS inspector attended three training

courses totaling $8,452 to prepare for deployment to Iraq. In FY 

2012, the most training money that OGS has spent on one employee is 

$3,700. Table 7 shows the total amount spent on employees who 

attended training during FYs 2010 and 2011, and the first quarter of 

FY 2012.

6

 We requested, and OGS provided, data for external training only. We did not review in-house training 

provided to OGS employees.

Review of Allegations of Misconduct and Mismanagement Within TSA's Office of Global Strategies 

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Table 7: Total Cost of Recent External Training by Employee 

$ FY 2010 FY 2011 FY 2012

$0-999 16 20 12 

$1,000-1,999 5 15 5 

$2,000-2,999 2 0 3 

$3,000-3,999 2 2 1 

$4,000-4,999 7 5 0 

$5,000-5,999 0 2 0 

$6,000-6,999 0 0 0 

$7,000-7,999 0 0 0 

$8,000-8,999 1 1 0 

$9,000-9,999 6 0 0 

$10,000 + 3 0 0

The ratio of male to female employees who have attended training

outside of OGS does not support the author's claim that management 

favors female employees when approving training. In FY 2010, 42 

employees attended external training courses. Of these 42 employees, 

14 (33 percent) were females. In FY 2011, 45 employees attended 

training, 12 (27 percent) of whom were females. In the first quarter of 

FY 2012, 21 employees attended training, 7 (33 percent) of whom 

were female. 

Twenty-one of 144 employees told us that they had been denied a

training opportunity. Employees gave many reasons for why their 

requests were denied. For example, four said that the continuing

resolution was the cause for their training request denial, and three

said that their denial was based on their workload. While four other 

employees chose not to elaborate on their answers, the remaining

responses varied from their lack of initiative to request training and the 

limited slots available for popular courses. One other employee felt 

that they were denied training because of age discrimination. 

However, this employee chose not to provide further explanation. 

Training records indicate that employees in headquarters; the Miami, 

Frankfurt, and Singapore Regional Operations Centers; TSARs; and 

IIRs have attended external training, while employees from the Los 

Angeles and Dallas Regional Operations Centers have not attended 

any outside training courses (see table 8). However, there was no 

Review of Allegations of Misconduct and Mismanagement Within TSA's Office of Global Strategies 

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ff�

 

 

indication that employees at these Regional Operations Centers had 

been denied external training opportunities that they had requested.

Table S: External Training Throughout OGS

Location FY 2010 FY 2011 FY 2012

Headquarters 11 12 5 

Miami 3 9 2 

Dallas-Fort Worth 0 0 0

Los Angeles 0 0 0 

Frankfurt 9 9 4 

Singapore 5 4 2 

TSAR 13 9 4 

IIR 0 2 2 

Locally employed 

sta

1 1 2 

�Locally employed staff are foreign nationals hired to provide administrative support

to the TSARs. OGS pays for their training, even though they are not OGS employees.

OGS management officials speculated that the approval of two 

employees, both of whom were females, to attend training at George 

Mason University's Mason Institute for Leadership Excellence at a 

cost of $4,000 each might have contributed to the author's allegation. 

In December 2010, the Office of Human Capital solicited nominations 

from Assistant Administrators for high-performing I- and J-band 

employees to attend the leadership program. The OGS Assistant 

Administrator selected and nominated three female employees 

assigned to OGS headquarters. Across TSA, Assistant Administrators 

nominated 16 employees for the program. An Agency Review Panel 

selected 10 candidates, 2 of whom were OGS nominees. On February

3, 2011, the Executive Resources Council approved the panel's

selections. Employees completed the training in March 2011. 

OGS officials also identified a second situation that may have led to 

this allegation. The Office of Personnel Management provides a 

Public Sector Leadership course through the Federal Executive 

Institute. This course, which costs $7,995, engages students in a 

rigorous curriculum to refine their leadership strategies and develop 

personal visions of public service. The Executive Resources Council 

was not involved in the selection of the candidates to attend the 

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Federal Executive Institute course. The then-Deputy Assistant 

Administrator for OGS explained that Office of Human Capital

announces the vacancies for the training. The OGS Directors 

nominated candidates, and he decided which candidates to recommend 

to the Assistant Administrator. He nominated one male and one 

female, both of whom were K-band employees. One was assigned to 

OGS headquarters and the other was a TSAR. The Federal Executive 

Institute leadership course was ultimately canceled due to faculty and 

enrollment issues, so no OGS employees attended and OGS incurred 

no cost. 

Hiring

Of the 144 employees we interviewed, 41 (28 percent) believe that 

hiring in OGS is unfair. Some examples they gave included 

noncompetitive selections, vacancies not being advertised, employees 

not interviewing for positions before being hired, and inexperienced or 

unqualified people being hired. Additionally, 46 employees (32 

percent) said that they were aware of instances where OGS created 

regional director, TSAR, supervisory desk officer, and other positions 

for specific individuals. 

However, it was apparent that many employees do not fully

understand all the methods that can be used to hire new employees, 

which contributes to perceptions that OGS hiring practices are unfair. 

TSA is an excepted service agency. It is not governed by most of Title 

5 USC, or the policies and procedures established by the Office of 

Personnel Management. TSA has many hiring flexibilities, including

the ability to hire competitively or noncompetitively. 

To determine whether OGS has recruited and hired personnel in 

accordance with the applicable TSA Management Directives, we 

reviewed selected administrative and personnel records. We 

determined that personnel selected for positions were qualified for 

those positions. Where interviews were used as a means to select 

candidates, those interviews involved a set of predetermined questions, 

which were asked of every candidate, and a weighted scoring system

for each question. Additionally, we noted that the process for hiring

personnel to fill the Supervisory Desk Officer and TSAR positions 

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involved a selection committee composed of senior OGS personnel, 

usually K-band Regional Managers, and a representative of the BMO. 

We also reviewed interview panel notes, as well as the lists of

recommended applicants referred to division directors. In most cases, 

OGS hired the recommended candidate. However, in the few 

instances where the recommended candidate was not chosen, the file 

contained evidence of the discussions resulting in the nonselection. 

Abuse of Power

The author of the letter alleged that OGS management's abuse of 

power is egregious, that OGS leadership manages through fear and 

intimidation, and employees are fearful of retribution and retaliation. 

Twenty-five of 144 employees we interviewed (17 percent) claimed 

that they personally felt intimidated, while 46 (32 percent) said they

were aware that other employees had felt threatened by management. 

These employees acknowledged that they were not directly informed 

by the employees who felt this way. Overall, 37 percent of the 

employees we spoke to have either personally felt threatened or 

intimidated by management or have heard of others who have.

The primary reason employees gave for feeling intimidated was that 

they receive constant reminders from OGS management that OGS 

would happily transfer employees to OSO or other offices within TSA 

should they fail to perform up to standards. Employees also asserted 

that members of the management team have strong personalities and 

are not receptive to opinions that may challenge their authority, and 

that opposing viewpoints are not encouraged. Senior managers 

acknowledge that they want employees who want to work in the 

organization, readily admit that they are trying to change the culture in 

OGS, and believe that they are holding every employee accountable. 

The data suggest that many employees either are, or know of others 

who are, not only uncomfortable with management's approach but 

also feel intimidated by it. It is not clear to what extent this sentiment 

stems from management intimidating the employees or from the 

employees' perception that they are being intimidated. The number of 

employees in OGS who felt they have been personally retaliated 

Review of Allegations of Misconduct and Mismanagement Within TSA's Office of Global Strategies 

Page 4S
 

 

against was not as high as the number of employees who said they

knew of others who feared reprisal. 

Out of 144 employees we interviewed, 15 (10 percent) said that they

were personally retaliated against by OGS management. A few chose 

not to discuss their situation, but those who did said that they were not 

considered for a supervisory position or for specific training. Thirtynine (27 percent) said that either they or other employees feared 

retaliation for disagreeing with or questioning the actions of OGS 

management. Employees said repeatedly that if they did not agree 

with all of management's actions, they would either be subject to 

retaliation or be ignored and labeled as a troublemaker. One employee 

asserted that fear of retaliation is widespread throughout all of TSA

and that the inherent fear and heightened sense of anxiety is mostly

based on one's personality. Most of these 39 employees chose not to 

explain why they fear reprisal for questioning management.

OGS Equal Employment Opportunity and MSPB Activity

Between October 1, 2007, and December 7, 2011, OGS employees 

filed six informal and six formal Equal Employment Opportunity

(EEO) complaints and eight MSPB appeals alleging various forms of 

discrimination, disability, nonsexual harassment, reprisal, 

whistleblower retaliation, or improper personnel actions. Some of 

these cases remain open and are in various stages of the complaint

process. Other cases were settled prior to the issuance of an Equal 

Employment Opportunity Commission or MSPB decision, and the 

remaining cases were decided in the agency's favor. There have been 

no findings of discrimination against the agency with regard to current 

or former OGS employees. 

Of the six informal complaints, two cases are pending, two cases were 

closed, and two cases were appealed to the MSPB. Of the six formal 

complaints-all of which were filed during FY 2010-three cases are 

pending hearings, one case was dismissed, one case was settled prior 

to a formal hearing, and one case was decided for the agency. 

Of the eight MSPB appeals, one case was withdrawn, four cases were 

settled prior to an MSPB decision, one case was initially decided 

Review of Allegations of Misconduct and Mismanagement Within TSA's Office of Global Strategies 

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against the agency but the decision was overturned upon appeal by

TSA, and the two remaining cases were decided for the agency. 

OGS Has Taken Actions to Address Employee Concerns

OGS Survey

Every year, DHS administers an All Employee Survey to evaluate the 

various components within DHS in 15 different areas concerning the 

workplace. After the All Employee Survey was administered in 2009, 

OGS conducted a follow-up survey to address the specific issues that 

were prevalent within OGS as indicated by the department-wide 

survey results. These issues were communications and business 

operations, which include awards, training, and development. The 

average percentage favorable in the communication category was 34 

percent, and the average percentage favorable in business operations 

was 39 percent. To address the communications issues, OGS

developed a Field Advisory Council, implemented annual visits to 

field locations by the OGS Senior Leadership Team, and began 

publishing a monthly newsletter. To address the business operations 

issues, OGS developed standardized job analysis tools, implemented 

an OGS employee of the quarter, developed performance metrics, and 

published the first OGS organizational chart. Another OGS-wide 

survey was conducted in 2011. The survey results showed higher 

favorable percentages in all 15 categories. The two lowest categories 

were still communications and business operations, but both showed 

improvement. The average percentage favorable in communications 

rose to 50 percent, and the average percentage favorable in business 

operations rose to 47 percent. 

The Business Management Office

OGS management has taken action to address employees' 

misperceptions concerning hiring by developing and presenting

training about the various avenues by which personnel can be hired. 

Known as the "BMO Road Show,� this training has been presented by

OGS' Human Resources Manager at all of the domestic Regional

Operations Centers, as well as at OGS headquarters and during a 

Review of Allegations of Misconduct and Mismanagement Within TSA's Office of Global Strategies 

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number of recent management conferences. The training seeks to 

educate the workforce concerning the various flexibilities available to 

TSA, as an excepted service agency, and how these are different from

what employees may be accustomed to from nonexcepted service 

federal agencies. 

Review of Allegations of Misconduct and Mismanagement Within TSA's Office of Global Strategies 

Page 4S
 
 

 

Appendix A

Purpose, Scope, and Methodology 

On May 18, 2011, the TSA Administrator received a letter from an 

anonymous source that contained several allegations of misconduct 

and mismanagement within TSA's Office of Global Strategies. 

The author opined that the issues were known to TSA's Deputy

Administrator and that she was protecting the OGS Assistant 

Administrator and Deputy Assistant Administrator by withholding

information from the Administrator. The Administrator referred 

the matter to us for review. Our objective was to determine 

whether the facts confirm allegations of management misconduct 

through favoritism, discrimination, abuse, and program 

mismanagement. 

We initially set aside the author's statement concerning possible

protection of OGS management by the TSA Deputy Administrator 

until we had a reason to pursue it. We found no evidence of these

activities. 

We did not undertake a comprehensive evaluation of OGS' airport 

and air carrier assessment program, in part because the 

Government Accountability Office (GAO) had already conducted 

one such review and was in the process of completing a second 

review at the time our fieldwork was beginning. Additionally, the

TSA Office of Inspection had conducted inspections of Global 

Compliance operations at TSA headquarters and at each of the

three domestic Regional Operations Centers that included reviews 

of the assessment program. We reviewed selected assessment

reports, the process used to track assessment results and corrective 

actions, and supporting documentation. 

We did not review OGS' travel records. OGS personnel travel 

extensively. Auditing these records would have prevented us from 

reviewing most of the author's allegations. Moreover, the TSA 

Office of Inspection had conducted an inspection of OGS travel 

records in the months just prior to the initiation of our review and 

was considering a reinspection at the time we started our review.

We reviewed applicable laws, regulations, and directives regarding

EEO and the various complaint processes. We also reviewed 

Review of Allegations of Misconduct and Mismanagement Within TSA's Office of Global Strategies 

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Appendix A

Purpose, Scope, and Methodology 

demographics; awards and promotion information; training files; 

hiring records; and applicable DHS, TSA, and OGS personnel 

standards, policies, and procedures. We did not review records 

concerning TSA Career Residency Program personnel assigned to 

OGS because this program is administered by the Office of Human 

Capital. Additionally, we reviewed the applicable laws, 

regulations, and directives pertaining to a number of the 

operational programs for which OGS is responsible. Finally, we 

reviewed TSA Office of Inspection reports and GAO performance 

audit reports and discussed the results with officials from both 

organizations. 

We conducted more than 225 interviews of officials within DHS, 

TSA, and OGS headquarters, and with current and former OGS 

employees. We conducted a site visit to the OGS Regional 

Operations Center in Miami to interview management and staff 

there. We conducted telephone interviews with OGS employees 

stationed at the Dallas, Miami, Los Angeles, Frankfurt, and 

Singapore Regional Operations Centers, as well as at various 

embassies around the world. TSA and OGS senior leadership 

cooperated and consulted with us throughout our review process. 

We asked 144 OGS employees specific questions designed to 

measure their perceptions of discrimination, retaliation, favoritism, 

and potential abuse of power. We judgmentally selected OGS 

employees from across the organization. This methodology

ensured that we had a good representation of the workforce in 

terms of age, sex, pay band, position, and geographic location. 

We began our fieldwork in June and ended it in November 2011. 

This review was conducted under the authority of the Inspector 

General Act of 1978, as amended, and according to the Quality

Standards for Inspections issued by the President's Council on 

Integrity and Efficiency.

Review of Allegations of Misconduct and Mismanagement Within TSA's Office of Global Strategies 

Page S0
 
 

Appendix B

Recommendations 

We recommend that the TSA Administrator:

Recommendation #1: Establish and implement timeframes for

issuing Emergency Amendments, including deadlines for TSA 

offices involved in reviewing and providing comments on them. 

Recommendation #2: Require rescreening for all passengers 

arriving at U.S. ports of entry from preclearance airports that fail to 

achieve comparable status. 

Review of Allegations of Misconduct and Mismanagement Within TSA's Office of Global Strategies 

Page S1
 
Appendix C

Management Comments to the Draft Report

Review of Allegations of Misconduct and Mismanagement Within TSA's Office of Global Strategies 

Page S2
 
Appendix C

Management Comments to the Draft Report

Review of Allegations of Misconduct and Mismanagement Within TSA's Office of Global Strategies 

Page S3
 
Appendix C

Management Comments to the Draft Report

Review of Allegations of Misconduct and Mismanagement Within TSA's Office of Global Strategies 

Page S4
 
 

Appendix D

Current TSAR Locations and Areas of Responsibility

Region TSAR Area of Responsibility 

Location 

Europe Berlin Austria, Germany, Hungary, Slovakia, Slovenia, Turkey

Brussels Belgium, European Union (EU)

The Hague Denmark, Finland, Greenland, Netherlands, Norway, 

Sweden

London Iceland, Ireland, United Kingdom

Madrid Cape Verde, Spain, Portugal

Paris France, Luxembourg, European Civil Aviation 

Conference (ECAC), Switzerland

Rome Albania, Bosnia and Herzegovina, Bulgaria, Croatia, 

Cyprus, Greece, Israel, Italy, Kosovo, Macedonia,

Malta, Romania, Serbia and Montenegro

Warsaw Armenia, Azerbaijan Republic, Belarus, Czech 

Republic, Estonia, Georgia, Kazakhstan, Kyrgyz,

Latvia, Lithuania, Moldova, Poland, Russia, Tajikistan, 

Turkmenistan, Ukraine, Uzbekistan 

Asia Pacific Bangkok Bangladesh, Burma, Cambodia, Laos, Thailand, 

Vietnam

Beijing China, Hong Kong, Macau, Mongolia, North Korea, 

South Korea

Kabul Afghanistan

Manila Kiribati, Marshall Islands, Micronesia, Palau, 

Philippines

Singapore Bhutan, Brunei, India, Indonesia, Malaysia, Maldives, 

Nepal, Pakistan, Singapore, Sri Lanka, Timor-Leste 

Sydney Austr

ala

alia, Cook Islands, Fiji, Nauru, New Guinea, New 

�e nd, Niue and Tuvalu, Papua New Guinea, Pitcairn, 

Samoa, Solomon Islands, Tahiti, Tokelau, Tonga, 

Tuvalu, Vanuatu

Tokyo French Polynesia, Japan, New Caledonia, Society

Islands, Taiwan, Wallis-Futuna 

Western 

Hemisphere

Brazil Brazil, Colombia, Ecuador, Paraguay

Buenos Aires Argentina, Bolivia, Chile, Peru, Uruguay

Caribbean 

North 

Anguilla, Aruba, Bermuda, Bonaire (Netherlands 

Antilles), Cayman Islands, Curacao, Montserrat, Saba, 

Review of Allegations of Misconduct and Mismanagement Within TSA's Office of Global Strategies 

Page SS
 
 

�

 

Appendix D

Current TSAR Locations and Areas of Responsibility

(Miami) St. Eustatius (Netherlands Antilles), St. Maarten, 

Suriname, UK Virgin Islands 

Caribbean 

South 

(Miami) 

Antigua and Barbuda, Barbados, Dominica, Grenada, 

Guyana, Jamaica, St. Kitts and Nevis, St. Lucia, St. 

Vincent and the Grenadines, Trinidad and Tobago 

Central

America 

(Miami) 

Belize, Costa Rica, Dominican Republic, El Salvador, 

Guatemala, Honduras, Nicaragua, Panama, Venezuela

Mexico City Mexico

Nassau Bahamas, Cuba, French Guiana, Guadeloupe, Haiti, 

Martinique, St. Barthelemy, Turks and Caicos

Ottawa Canada

Africa / Abu Dhabi Bahrain, Iran, Kuwait, Oman, Qatar, UAE

Middle East Amman Algeria, Egypt, Jordan, Lebanon, Libya, Mauritania, 

Morocco, Palestine Territories, Saudi Arabia, Syria, 

Tunisia, Western Sahara

Johannesburg Angola, Botswana, Congo, Comoros, Equatorial 

Guinea, Gabon, Lesotho, Madagascar, Malawi, 

Mauritius, Mozambique, Namibia, S�o Tom and

Pr�ncipe, South Africa, Swaziland, �ambia, �imbabwe

Nairobi Burundi, Central African Republic, Chad, Democratic 

Republic of Congo, Djibouti, Eritrea, Ethiopia, Kenya, 

Rwanda, Seychelles, South Sudan, Somalia, Sudan, 

Tanzania, Uganda

West Africa

(Arlington, 

VA - HQ)

Benin, Burkina Faso, Cameroon, C�te d'Ivoire, Gambia, 

Ghana, Guinea-Bissau, Liberia, Mali, Niger, Senegal, 

Sierra Leone, Togo

AFRICOM

(Stuttgart, 

Germany)

Multilateral Organizations and Projects: Saudi OPMMOI, ICAO, Safe Skies for Africa, African Civil 

Aviation Commission, Arab Civil Aviation 

Commission, Banjul Accord Group, Arab League,

African Union, Southern African Development 

Community

Review of Allegations of Misconduct and Mismanagement Within TSA's Office of Global Strategies 

Page S6
 
 

 

 

 

 

 

 

Appendix E

TSARs with Responsibility for the Caribbean 

TSAR Nassau 

Country Airport Airport Name City 

Code 

Bahamas ASD Andros Town International Airport Andros Town

BIM South Bimini Airport South Bimini

ELH North Eleuthera Airport N. Eleuthera

FPO Grand Bahama International Airport Freeport

GGT Exuma International Airport Great Exuma Island

GHB Governor's Harbour Airport Governor's 

Harbour

MHH Marsh Harbour Airport Marsh Harbour, 

Abaco

NAS Lynden Pindling International Airport Nassau

TBI The Bight Airport New Bright

TCB Treasure Cay Airport Treasure Cay

�SA San Salvador Airport San Salvador

Cuba CFG Jaime Gonzalez Airport Cienfuegos

CMW Ignacio Agramonte International

Airport 

Camaguey

GAO Mariana Grajales Airport Guantanamo

HAV Jose Marti International Airport Havana

HOG Frank Pais Airport Holguin

SCU Antonio Maceo International Airport Santiago

French 

Guiana

Guadeloupe PTP Le Raizet Airport Pointe-a-Pitre 

Haiti CAP Cap-Haitien International Airport Cap-Haitien

PAP Toussaint L'Ouverture International 

Airport 

Port-au-Prince

Martinique FDF Le Lamentin Airport Fort De France 

St. 

Barthelemy

Turks and 

Caicos

PLS Providenciales International Airport Providenciales

Total LPDs: 22 

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Page S7
 
 

 

 

 

 

 

 

 

 

 

Appendix E

TSARs with Responsibility for the Caribbean 

TSAR Caribbean North

Country Airport Airport Name City 

Code 

Anguilla A�A Wallblake Airport The Valley

Aruba AUA Queen Beatrix International Airport Oranjestad

Bermuda BDA Bermuda (L.F. Wade) International

Airport 

Hamilton 

Bonaire 

(Neth. 

Antilles) 

BON Flamingo International Airport Kralendijk

Cayman

Islands

GCM Owen Roberts International Airport Georgetown

Curacao CUR Hato International Airport Willemstad

Montserrat

Saba 

St. Eustatius 

(Neth. 

Antilles) 

St. Maarten S�M Princess Juliana International Airport Philipsburg

Suriname

UK Virgin 

Islands 

EIS Terrance B. Lettsome International

Airport 

Beef Island

Total LPDs: S

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Page SS
 
 

 

 

 

 

 

 

 

 

 

 

 

 

Appendix E

TSARs with Responsibility for the Caribbean 

TSAR Caribbean South

Country Airport Airport Name City 

Code 

Antigua and 

Barbuda

ANU V.C. Bird International Airport St. John's 

Barbados BGI Grantley Adams International Airport Bridgetown

Dominica DOM Melville Hall Airport Marigot

Grenada GND Maurice Bishop International Airport Point Salines

Guyana GEO Cheddi Jagan International Airport Georgetown

Jamaica KIN Norman Manley International Airport Kingston

MBJ Sangster International Airport Montego Bay

St. Kitts and 

Nevis 

NEV Vance W. Amory International Airport Charlestown

SKB Robert L. Bradshaw International 

Airport 

Basseterre 

St. Lucia SLU George F. L. Charles Airport Castries 

UVF Hewanorra International Airport Vieux-Fort 

St. Vincent 

and the 

Grenadines

Trinidad

and Tobago

POS Piarco International Airport Port of Spain 

TAB Crown Point International Airport Scarborough

Total LPDs: 13 

TSAR Central America

Country Airport Airport Name City 

Code 

Dominican

Republic 

LRM La Romana International Airport La Romana

POP Gregorio Luperon International Airport Puerto Plata 

PUJ Punta Cana International Airport Punta Cana 

SDQ Las Americas International Airport Santo Domingo

STI Santiago Municipal International 

Airport 

Santiago

Total LPDs: S

Review of Allegations of Misconduct and Mismanagement Within TSA's Office of Global Strategies 

Page S9
 
 

Appendix F

Major Contributors to this Report

William J. McCarron, Chief Inspector

Wayne A. Ekblad, Senior Inspector

Anne Y. Cho, Inspector

Nicholas P. Ketter, Inspector 

Review of Allegations of Misconduct and Mismanagement Within TSA's Office of Global Strategies 

Page 60
 
 

 

 

 

 

 

 

 

Appendix G

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 

TSA Audit Liaison

Director of Local Affairs, Office of Intergovernmental Affairs 

Office of Management and Budget

Chief, Homeland Security Branch 

DHS OIG Budget Examiner

Congress

Congressional Oversight and Appropriations Committees, as 

appropriate

Review of Allegations of Misconduct and Mismanagement within TSA's Office of Global Strategies 

Page 61
 
 

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