Defense Transportation: DOD Needs to Take Actions to Improve the Transportation of Hazardous Material Shipments
Published: 2014-05-01T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: Over 3 billion tons of HAZMAT are transported by commercial carriers in the United States each year. DOD accounted for about 1.6 million HAZMAT shipments in fiscal year 2013, using commercial and military carriers. These shipments can be high risk and highly sensitive and if improperly handled, labeled, or packaged could result in the loss of life, property damage, and harm to national security interests.
The National Defense Authorization Act for Fiscal Year 2013 mandates GAO to review DOD's guidance, policies, and procedures regarding HAZMAT shipments. GAO examined the (1) statutes, regulations, guidance, policies, and procedures that govern DOD's handling, labeling, and packaging of HAZMAT shipments to support military operations and (2) extent to which DOD faces any challenges in implementing its policies and procedures for transporting HAZMAT in a safe, timely, and cost-effective manner. GAO examined DOD's and DOT's regulations and related DOD documentation for the transport of HAZMAT and found the 2009-13 data it examined sufficiently reliable for the purposes of the review.
section_title: What GAO Found
paragraphs: The handling, labeling, and packaging of hazardous materials (HAZMAT) shipments are governed by a complex framework of statutes and regulations prescribed by multiple civilian and military entities (see figure below). The Hazardous Materials Transportation Act is the primary statutory regime governing the transport of HAZMAT in the United States. To implement the act, the Department of Transportation (DOT) issued the Hazardous Materials Regulations. The Defense Transportation Regulation prescribes how the Department of Defense (DOD) is to transport HAZMAT.
DOD has experienced some challenges in implementing HAZMAT regulations and other guidance, which can adversely affect the safe, timely, and cost-effective transportation of HAZMAT. For example, GAO found the following:
Improper documentation and packaging of HAZMAT led to delays at DOD transportation aerial ports. DOD data show that about 27 percent of HAZMAT received at all five major domestic military aerial ports over the past 5 fiscal years were delayed, primarily due to noncompliant documentation and packaging.
At least 44 times during fiscal years 2012 and 2013, DOD installations did not provide commercial carriers with access to secure hold areas for arms, ammunition, and explosives shipments or assist them in finding alternatives, as required by DOD regulations. Although there were about 70,891 of these types of arms, ammunition, and explosives shipments in fiscal years 2012 and 2013, not providing secure hold for even a small percentage of these sensitive shipments poses a risk to public safety and national security.
DOD may determine which carriers should be eligible to transport its most-sensitive HAZMAT shipments using a safety score that lacks sufficient information to reliably assess safety performance for many carriers. DOD uses DOT's Safety Measurement System scores to determine which carriers are eligible to participate in its Transportation Protective Services program. However, in February 2014 GAO found that scores from many carriers lack sufficient safety performance data to reliably compare them with other commercial carriers' scores.
section_title: What GAO Recommends
paragraphs: GAO recommends that DOD improve the documentation and secure hold of HAZMAT shipments and examine limitations on data used to select certain HAZMAT carriers. DOD generally agreed with the recommendations but requested one be directed to a different office. GAO agreed and made the associated change.

section_title: Letter
paragraphs: Over 3 billion tons of hazardous materials (HAZMAT) are transported by  commercial carriers in the United States each year, with an estimated 1.4  million HAZMAT shipments per day. These range from sensitive  materials commonly considered to pose a risk to national security (e.g.,  arms, ammunition and explosives, and nuclear-weapons-related  materials) to those associated with everyday use (e.g., chlorine, fire  extinguishers, and lithium batteries). HAZMAT at both ends of this  spectrum can pose a significant threat to transportation workers,  emergency responders, and the general public if the HAZMAT shipment  is not properly handled, labeled, and packaged for transportation. Within  the United States, the Department of Transportation (DOT) is the primary  federal agency responsible for issuing regulations for the safe transport of  HAZMAT in intrastate, interstate, and foreign commerce.
The Department of Defense (DOD) transported approximately 1.6 million  HAZMAT shipments in fiscal year 2013 using a mix of commercial and  military carriers. The shipments the department transports can be high  risk (e.g., explosives and toxins) as well as highly sensitive (e.g., missiles)  and, if improperly handled, labeled, or packaged, could result in the loss  of life, property damage, and harm to national security interests. DOD  relies heavily (for about 90 percent of its total HAZMAT shipments) on  commercial carriers to transport HAZMAT both within the United States  and worldwide. Within DOD, the U.S. Transportation Command  (TRANSCOM) is the functional combatant command charged with  providing transportation services to the other combatant commands,  military services, and defense organizations.
The National Defense Authorization Act for Fiscal Year 2013 mandates  GAO to review DOD’s guidance, policies, and procedures for the  handling, labeling, and packaging of HAZMAT shipments, including how  the guidance, policies, and procedures contribute to the safe, timely, and  cost-effective handling of such material, among other matters. respond to this mandate, we examined the (1) statutes, regulations,  guidance, policies, and procedures that govern DOD’s handling, labeling,  and packaging of HAZMAT shipments to support military operations and  (2) extent to which DOD faces any challenges in implementing its policies  and procedures for transporting HAZMAT in a safe, timely, and cost- effective manner.
See Pub. L. No. 112-239, § 372 (2013).
Pub. L. No. 93-633, tit. I (1975) (codified as amended at 49 U.S.C. §§ 5101-5128). its policies and procedures for transporting HAZMAT in a safe, timely, and  cost-effective manner, we selected and visited several DOD locations  involved in transporting HAZMAT, including the U.S. Defense Supply and  Distribution Center (Richmond, Virginia); Dover Air Force Base (Dover,  Delaware); and Norfolk Naval Base (Norfolk, Virginia). We selected these  locations because they provided a cross section of the various modes of  transportation and hazardous-material classes. We focused our review on  surface and air modes of transport—on surface transport because most  individual shipments are transported by highway (94 percent in fiscal year  2013) and on air transport because that mode generally has more- restrictive requirements (e.g., the quantity of certain HAZMAT like acetic  acid, a class 8 HAZMAT, allowed on a passenger air transport is lower  than other modes due to its corrosive properties). We reviewed data from  TRANSCOM’s Global Air Transportation Execution System for 5 fiscal  years (2009 through 2013) and Defense Transportation Tracking System  records for 2 fiscal years (2012 and 2013) to analyze records related to  pretransportation and transportation functions (e.g., handling, labeling,  and packaging activities and the transport of HAZMAT in commerce to  the final destination point), respectively. We compared data from those  records with requirements in the Defense Transportation Regulation and  found that the data we examined were sufficiently reliable for the  purposes of identifying challenges and the extent to which they affect the  transport of HAZMAT. To corroborate our understanding of the  documents and data we analyzed, we interviewed officials from the Office  of the Secretary of Defense; the Office of the Deputy Assistant Secretary  of Defense for Transportation Policy; the Defense Logistics Agency; the  Army, the Air Force, the Navy, and the Marine Corps; and DOT’s Pipeline  and Hazardous Materials Safety Administration. See appendix I for more  information on our scope and methodology.
We conducted this performance audit from April 2013 to May 2014 in  accordance with generally accepted government auditing standards.  Those standards require that we plan and perform the audit to obtain  sufficient, appropriate evidence to provide a reasonable basis for our  findings and conclusions based on our audit objectives. We believe that  the evidence obtained provides a reasonable basis for our findings and  conclusions based on our audit objectives.
subsections: section_title: Background
subsections: section_title: HAZMAT Overview and Role of the Department of Transportation (DOT)
paragraphs: HAZMAT is any substance or material that the Secretary of  Transportation has determined is capable of posing an unreasonable risk  to health, safety, or property when transported in commerce. The  Secretary of Transportation designates HAZMAT under the Hazardous  Materials Transportation Act and its implementing regulations. Within  the federal government, DOT has the primary responsibility to issue  regulations for the safe transport of HAZMAT in intrastate, interstate, and  foreign commerce. To accomplish this mission, DOT issues HAZMAT  regulations and provides other services to the transportation community  and emergency responders—such as training, enforcement, technical  support, information, and policy guidance—to protect the public against  the safety risks inherent in transporting HAZMAT.
According to DOT’s Office of Hazardous Materials Safety, an estimated  1.4 million HAZMAT shipments are transported in the United States each  day on average. These shipments amount to more than 3 billion tons of  HAZMAT transported every year. While only about 43 percent of all  HAZMAT tonnage is transported by highway, that tonnage accounts for  approximately 94 percent of the individual shipments. Air, water, rail, and  pipeline constitute the remaining HAZMAT transportation modes, with air  generally being the most restrictive (due to aircraft cargo limitations and  load restrictions).
DOT uses a United Nations classification system to categorize all  HAZMAT into nine classes and ensure its safe storage, handling,  transportation, use, and disposal. Each of the nine HAZMAT classes is  defined by a specific set of parameters—usually characterized by  chemical properties (e.g., an oxidizer material) or inherent physical  properties (e.g., a corrosive material) or as possibly posing a health  hazard (e.g., a poisonous substance). Figure 1 shows examples of DOT’s  labels, warning labels, and hazard warnings for the nine classes of  HAZMAT, which can be further subdivided into divisions (e.g., class 5 is  divided into 5.1 and 5.2).
For example, HAZMAT in these classes could include explosives, which  are class 1; gasoline, class 3; and lithium batteries, class 9.
section_title: DOD Management of HAZMAT Transportation
paragraphs: TRANSCOM is DOD’s single manager for transportation, other than  service-unique or theater-assigned assets.of three military service component commands that manage the  movement of DOD shipments, including HAZMAT—the Army’s Military   The command is composed  Surface Deployment and Distribution Command, the Navy’s Military  Sealift Command, and the Air Force’s Air Mobility Command. The Army’s  Military Surface Deployment and Distribution Command provides  worldwide common-use ocean terminal services and traffic-management  services, conducts port operations at sealift terminals, and plans,  transports, and tracks shipments transported by surface and rail. The  Navy’s Military Sealift Command transports shipments over water using a  mixture of government-owned and commercial ships. The Air Force’s Air  Mobility Command transports shipments to destinations anywhere around  the world by military or commercial carriers by air and serves as the  single port manager for common-user aerial ports.
DOD installations, bases, or sites appoint personnel to assist with traffic- management functions. These traffic-management functions include, but  are not limited to, providing efficient, responsive, and quality  transportation services. These duties also include assisting with the  handling, labeling, and packaging of HAZMAT shipments prior to offering  them to carriers for transport. Shipments may originate at a vendor (e.g.,  a manufacturer) or DOD location (e.g., a Defense Logistics Agency  depot). Moreover, a manufacturer might use a separate commercial  carrier than one used by DOD to deliver its parts to the DOD installation  that ordered them.
Shippers, carriers, and receivers carry out the three basic roles of the  transportation system. A shipper may be a DOD entity (e.g., the Defense  Logistics Agency), or a contracted commercial vendor (e.g., a  manufacturer) where a shipment originates. A carrier may be a DOD  entity or a private-sector individual or company that transports shipments  from the shipper to the receiver. A receiver is the DOD entity that is the  final destination point for the shipment. In cases in which shipments are  destined for overseas areas, the shipments may be transported through  central receiving points, such as one of DOD’s five aerial ports or a  Defense Logistics Agency depot, before being sent to the final destination  point. In figure 2, we list the specific functions that a shipper, carrier, and  receiver might perform to transport HAZMAT.
A shipper is responsible for performing several functions prior to the  movement of HAZMAT. These pretransportation functions include, but  are not limited to, the following:
Determining the hazard class and mode of transportation: The shipper  reviews the Hazardous Materials Regulations to properly identify the  hazardous materials in the shipment. This information is needed to  determine the packaging, marking, and labeling,requirements for the specific type of HAZMAT being transported.
Packaging and labeling: Once the mode of transportation has been  determined, the shipper selects the appropriate packaging and  labeling, fills the package, secures a closure on the package, and  affixes the appropriate labels.
Documentation: HAZMAT shipments that require documentation (as  shown in fig. 3 and fig. 4) must describe the HAZMAT and the total  quantity of the HAZMAT being shipped, provide emergency response  information, and provide certification by the shipper that the HAZMAT  is in proper condition for transportation.
Loading, blocking, and bracing: The HAZMAT package is to be  appropriately loaded, blocked, and braced in a freight container or  transport vehicle. During this process, the HAZMAT may be  segregated in a transport vehicle to ensure that it is not transported  with an incompatible shipment.
Selecting, providing, or affixing placards: The container and the  carrier’s vehicle are to be properly marked to identify that the vehicle  contains HAZMAT.
Once a shipper has completed the required pretransportation functions, a  carrier takes possession of the HAZMAT shipment and performs the  transportation functions. Transportation functions include the  movement, loading incidental to movement, unloading incidental to  movement, and storage incidental to movement. Transport may involve  a single mode of transport (e.g., by highway or aircraft) or it can be  multimodal—for example, moving first by surface (by highway or rail) and  then through a central receiving point, such as an aerial port (for aircraft)  or a depot. At the end of the transportation function, a carrier delivers the  HAZMAT shipment to its final destination point, where a receiver takes  possession of the HAZMAT shipment for immediate use or storage for  later use.
section_title: The Handling, Labeling, and Packaging of DOD HAZMAT Shipments Is Governed by a Complex Framework of Statutes and Regulations
subsections: section_title: A Complex Framework of Statutes and Regulations Governs DOD’s Handling, Labeling, and Packaging of HAZMAT Shipments
paragraphs: When transporting HAZMAT, there is a complex framework of statutes  and regulations prescribed by multiple civilian and military entities that  must be considered and evaluated to ensure safe, secure, and efficient  transport. The Hazardous Materials Transportation Act, enacted in 1975  and since amended, is the primary statutory regime governing the  transport of HAZMAT in the United States. The purpose of the act is to  protect against the risks to life, property, and the environment that are  inherent in the transport of HAZMAT in intrastate, interstate, and foreign  commerce.Regulations, located in Title 49 of the Code of Federal Regulations, which  generally govern the handling, labeling, packaging, and transportation of   To implement the act, DOT issued the Hazardous Materials  HAZMAT shipments in commerce, among other activities. The  regulations include specific guidance pertaining to each of the nine  classes of HAZMAT on the basis of their composition, level of danger,  and mode of transport. With regard to DOD, the Defense Transportation  Regulation prescribes how DOD is to transport HAZMAT. Specifically, the  Defense Transportation Regulation incorporates or references  requirements from DOT’s Hazardous Materials Regulations, as well as  various international- and country-specific regulations or standards for  transporting HAZMAT shipments by air and water. In figure 5, we  illustrate the statutory and regulatory elements that govern DOD’s  handling, labeling, and packaging of HAZMAT shipments.
Applying the different regulations governing the transportation of a  specific HAZMAT class to the mode of transportation can be complex for  service transportation officials and requires careful reading of all  applicable regulations. As an example, when shipping acetyl chloride  (flammable liquid, class 3 HAZMAT) the shipper must review several  sources to determine how to properly ship the item. If the shipper intends  to ship the HAZMAT on a commercial aircraft carrying passengers, the  Hazardous Materials Regulations indicate that no more than 1 liter of this  liquid per package can be shipped because of the risk posed by  transporting HAZMAT of that classification. If the HAZMAT is being  shipped by military aircraft or on an international flight, additional  requirements and limitations may need to be applied. On the other hand,  if carriers transport acetyl chloride by highway, they may be able to  transport greater quantities.
DOD may also ship DOD-unique HAZMAT items that are not addressed  in DOT’s Hazardous Materials Regulations or for which DOD needs to  seek a waiver or approval. In these cases, the Hazardous Materials  Regulations and DOT guidance specify a process that any commercial or  government entity can use to apply for a DOT waiver in the form of a  special permit or approval providing relief from requirements in the  Hazardous Materials Regulations. DOD shipments may also use  certificates of equivalence, which are approvals issued by DOD itself in  instances where a packaging design differs from the requirements of the  Hazardous Materials Regulations. Certificates of equivalence certify that  the packaging equals or exceeds the comparable requirements of the  Hazardous Materials Regulations. DOD shippers can use special  permits or approvals from DOT or certificates of equivalence from DOD to  handle department-unique HAZMAT shipments in a way commensurate  with the DOT requirements. For example, according to officials, missiles  transported in certain configurations are not standard items covered by  the Hazardous Materials Regulations. Therefore, DOD obtained an  approval from DOT that indicates the type of packaging and container to  be used to transport this item, which, according to officials, is equal to or  exceeds the requirements of the Hazardous Materials Regulations.  Similarly, for new items that are not mentioned in the Hazardous  Materials Regulations, such as certain DOD-specific or emerging  HAZMAT (e.g., lithium batteries with a metal casing) DOD might obtain a  waiver that identifies how these items will be packaged and transported.
section_title: DOD Has Developed Regulations and Other Guidance for Circumstances Unique to the Department
paragraphs: In addition to the statutory and regulatory elements discussed above,  DOD has developed additional guidance to address specific  circumstances that are either not covered in the existing framework of  statutes and regulations or are areas where the department believes  additional or different requirements are needed. For example:
The Defense Transportation Regulation addresses the policies,  procedures, and responsibilities for transporting HAZMAT by military  aircraft. Additionally, Air Force Manual 24-204 (Interservice)  identifies procedural exceptions in the context of tactical, contingency,  or emergency airlift. Because of the increased risk to the aircraft,  aircrew, and participants, these procedural exceptions must only be  used when there is a validated operational requirement. For example,  in certain circumstances DOD may be able to use a single Shipper’s  Declaration for Dangerous Goods to identify and certify more than one  type of hazardous material when shipped under a single tracking  number.
For arms, ammunition, and explosives and certain classified  shipments, the Defense Transportation Regulation contains  requirements, procedures, and responsibilities related to the  Transportation Protective Services program. Transportation Protective  Services include a series of safeguards additional to those found in  the Hazardous Materials Regulations such as, depending on the  shipment, satellite tracking of the carrier vehicle using the Defense  Transportation Tracking System and the use of two drivers with  security clearances to provide constant surveillance. TRANSCOM’s  Surface Deployment and Distribution Command provides approval for  certain commercial carriers to offer these Transportation Protective  Services after determining that they meet safety performance  thresholds, among other requirements.
According to Army health officials, the Defense Transportation  Regulation also contains more-stringent training requirements for  personnel shipping medical HAZMAT. As described by officials, the  Defense Transportation Regulation and other guidance requires  medical personnel who package and ship hazardous materials be  trained and certified to do so at one of the DOD-approved hazardous- materials transportation courses. Specifically, the Defense  Transportation Regulation indicates that anyone involved with the  transportation of pathogens or etiologic agents who manages,  packages, certifies, or prepares laboratory samples and specimens or  regulated medical waste for transport by any mode may satisfy the  training requirement through specific courses offered by the Army   According to officials, these training  Public Health Command. requirements extend to those personnel who package and ship  biological select agents and toxins as well.
section_title: DOD Has Experienced Some Challenges in Implementing HAZMAT Policies and Procedures, Which Can Adversely Affect the Safe, Timely, and Cost-Effective Transportation of HAZMAT
paragraphs: According to TRANSCOM officials, in general DOD HAZMAT shipments  arrive at their final destination without incident or delay; however, the  department faces some challenges ensuring the safe, timely, and cost- effective transportation of some HAZMAT shipments. According to DOD  data, for HAZMAT transported by surface and air, improper  documentation and packaging have led to transportation delays. In a  limited number of instances with a potential for public safety and national  security consequences, DOD installations did not provide carriers  transporting sensitive arms, ammunition and explosives HAZMAT with  access to secure hold areas or assist them in locating the nearest  alternate means to secure those shipments. In addition, the reliability of  safety performance data calls into question DOD’s process for selecting  eligible, and evaluating current, HAZMAT carriers to transport arms,  ammunition, explosives, and sensitive and classified shipments.
subsections: section_title: DOD HAZMAT Shipments Were Improperly Documented and Packaged
paragraphs: According to DOD information that we analyzed for air and surface  HAZMAT shipments and according to officials, a substantial number of  HAZMAT shipments were not documented and packaged in accordance  with the Defense Transportation Regulation, which resulted in delays. To  ensure the safe and secure transport of HAZMAT, DOD delayed the  transport of these shipments until the documentation or packaging issues  were resolved. According to agency officials we interviewed, these  shipment delays can be as short as a few hours or last several weeks,  depending on the nature of the issue. For example, regarding HAZMAT  shipments to be transported by air, Global Air Transportation Execution  System data show that, of the 246,747 total shipments of HAZMAT  received at all five major domestic military aerial ports for fiscal years  2009 through 2013, 67,149 shipments (or 27 percent) were delayed— primarily because they were not in compliance with the Defense  Transportation Regulation requirements for documentation and  packaging.
While the Surface Deployment and Distribution Command  data are not aggregated in the same format as the air shipment data,  according to agency officials, improper documentation and packaging  cause some delays in transportation of surface HAZMAT shipments.  According to DOD officials, improper documentation and packaging also  result in delays for the sea transportation mode. Agency officials stated  that the specific documentation and packaging issues that resulted in  delays varied. Following are examples that illustrate the types of  instances that we identified during the course of our review in which,  according to officials, the documentation and packaging of HAZMAT  shipments were not in compliance with the Defense Transportation  Regulation requirements and resulted in delays:  Improper documentation (air): At a major aerial port we visited, we  identified examples of HAZMAT shipments containing acetaldehyde  (flammable liquid, class 3 HAZMAT) that were delayed because,  according to officials, they were missing the Shipper’s Declaration for  Dangerous Goods. The Defense Transportation Regulation requires  that when transporting HAZMAT by air, the shipper must complete a  Shipper’s Declaration for Dangerous Goods for the shipment. In  another example, at a depot we visited, we identified various  HAZMAT shipments of lithium batteries that were also delayed  because, according to officials, they had improper HAZMAT shipping  names on the bill of lading.  Improper documentation (surface): We found instances of similar  documentation problems for surface transportation that led to  HAZMAT transportation delays. Reviewing examples of  Transportation Discrepancy Reports—which are used to document  shipper-related discrepancies, among other things—we found that  improper documentation is a major cause for delays. For example, in  the reports we found instances where the required Dangerous Goods  Declaration forms were missing and where the proper HAZMAT  material name was not included with the shipment as required by the  Defense Transportation Regulation.  Improper packaging (air): At a major aerial port we visited, we  identified a shipment of rusted acetylene (flammable gas, class 2.1  HAZMAT) gas cylinders that were delayed in transport because,  according to officials, they had arrived at the aerial port improperly  packaged—stacked on top of one another in lidless wooden boxes  (see fig. 6). According to military aerial port officials, to comply with  the requirements of the Defense Transportation Regulation the rusted  cylinders need to be recertified to ensure the integrity of the  packaging before they are safe for air transport and may not be  stacked on top of one another. Officials told us that, as a result of  improper packaging, the potentially dangerous acetylene cylinders  were delayed at the aerial port until the packaging discrepancies  could be resolved by the shipper.
Improper packaging (air): We observed a dented drum of flammable,  toxic liquid (class 3 HAZMAT) that aerial port officials identified as  improperly packaged under the Defense Transportation Regulation  because of its potential to leak (see fig. 7). The military aerial port  officials pointed out that, when transported by air, leaking HAZMAT  drums can cause serious damage to DOD personnel and aircraft  transporting them.
Improper packaging (surface): Similarly, reviewing samples of  Transportation Discrepancy Reports, we found instances of improper  packaging. For example, we found a report of a shipment of helium  gas (nonflammable gas, class 2.2 HAZMAT) in a container that,  according to the report, was not properly secured (blocked and  braced) for shipment. Another report identified an instance where a  grenade (explosive, class 1.1 HAZMAT) arrived inside an armored  vehicle instead of proper packaging for an explosive. Additionally, we  found a report of a bottled oxygen (nonflammable gas, class 2.2  HAZMAT) shipment that arrived via highway improperly packaged for  air shipment. According to the report, the material must be packed in  a flame penetration and thermal-resistant package aboard an aircraft  to prevent a potentially serious accident.
During the course of our review, DOD officials pointed out several  potential causes for these types of noncompliance. While the DOD  officials we interviewed provided information about specific HAZMAT  shipment delays, none stated a holistic understanding of the root causes  resulting in HAZMAT transportation delays. Specifically we found the  following:
DOD officials from a surface port we interviewed told us that some  DOD personnel and commercial shippers lack experience and training  on HAZMAT documentation and packaging. Additionally, at an aerial  port, officials believed that some commercial shippers also lacked  familiarity with DOD HAZMAT documentation and packaging  requirements and some shippers did not have HAZMAT-certified  personnel to ensure proper HAZMAT documentation and packaging.
Aerial port officials told us that normal personnel rotations  exacerbated training problems because experienced personnel  regularly moved to other positions, leaving less-experienced  personnel behind to document and package HAZMAT shipments.
Aerial port officials also told us that shippers have limited incentives to  comply with DOD regulations because the aerial port itself has no way  to discipline shippers that regularly transported improperly  documented or packaged HAZMAT shipments knowing that in some  cases the aerial port would fix the shipment.
At another aerial port and DOD installation we visited, officials  reported that miscommunication among the shipper, carrier, or  receiver (incorrect shipping address or modes of transportation  needed to transport the shipment) causes delays for HAZMAT  shipments.
Additionally, DOD officials at the surface and aerial ports we visited noted  that they lacked the ability or authority to correct the root causes they  suspected to be the source of delays. As a result, when a HAZMAT  shipment arrives with improper packaging, DOD officials at these ports  can either correct the problem themselves by repackaging the shipment  or attempt to contact the shipper to correct the issue.
In 2008, the Office of the Deputy Assistant Secretary of Defense for  Transportation Policy commissioned a study to address DOD’s  unacceptable level of delayed HAZMAT shipments. According to the  Frustrated Cargo Analysis Final Project Report, the study’s scope was to  reduce the effect of these delays by first defining the scope of the  problem, developing a consensus on root causes, and providing a data- centric solution to the problems. While the 2008 report had several  findings that identified causes for delays, including improper  documentation and packaging of HAZMAT at an aerial port and a  distribution depot, DOD has not resolved the problems addressed in that  report or followed up on those findings with a more-recent analysis of the  root causes for the delays that the department continues to experience.  Moreover, we visited one of the sites identified in the report and observed  that the same causes for delays with regard to documentation and  packaging of HAZMAT persisted at that location. Additionally, we visited a  different distribution depot and noted the same causes for delays.
According to the Office of Management and Budget’s Management’s  Responsibility for Internal Control, federal agencies should establish or  maintain internal control to achieve effective and efficient operations and  compliance with applicable regulations—in this case, the Defense  Transportation Regulation and related guidance. Moreover, federal  internal control standards call for agency management officials to  promptly evaluate findings from audits and other reviews showing  deficiencies, determine proper actions in response to those findings and  recommendations, and complete, within established time frames, all  actions that correct or otherwise resolve the matters brought to  management’s attention. However, DOD has not conducted a recent,  holistic analysis to determine the root causes for the significant number of  delays in HAZMAT shipments resulting from improper documentation and  packaging. DOD officials acknowledged that they do not have this current  information and agreed that it would be helpful in identifying and  addressing issues causing delayed HAZMAT shipments. Without such  information, DOD cannot adequately ensure compliance with the Defense  Transportation Regulation. These delays have resulted in DOD’s  committing resources—personnel, storage space, and packing  materials—to ensure that the delayed cargo can ultimately be transported  safely.
section_title: DOD Installations Have Not Secured Sensitive Arms, Ammunition, and Explosives Shipments Delivered by Highway in a Timely Manner
paragraphs: According to reports from the Surface Deployment and Distribution  Command Operations Center’s Defense Transportation Tracking System,  DOD installations did not provide commercial carriers access to a secure  hold area for at least 44 out of 70,891 sensitive arms, ammunition, and  explosives shipments or did not assist carriers in finding alternative  means to secure those shipments in fiscal years 2012 and 2013.  Although these instances represent a relatively small percentage of the  overall number of sensitive arms, ammunition, and explosives shipments,  not providing secure hold for even a small percentage of these sensitive  shipments poses a risk to public safety and to national security. While we  found no evidence of severe incidents resulting from these instances  where commercial carriers transporting sensitive HAZMAT were not  provided access to secure hold areas, the potential high-risk  consequences to public safety and national security of this type of failure  are significant. A secure hold area is a location designated for the  temporary parking of carrier vehicles transporting DOD-owned arms,  ammunition, and explosives and other sensitive material.
See Department of Defense, Physical Security of Sensitive Conventional Arms,  Ammunition, and Explosives (AA&E), Manual 5100.76, encl. 10, para. 7.a (Apr. 17, 2012). location (or other approved location such as a carrier-owned facility) that  can provide secure hold.
To determine which DOD installations have the ability to provide secure  hold, shippers and carriers use the Transportation Facilities Guide. The  Transportation Facilities Guide lists DOD installation information including  those that offer secure hold areas and their hours of operation, among  other things. DOD installations are required to update their Transportation  Facilities Guide records immediately whenever critical operational  changes are made, such as changes in operating hours or installations  closures. Otherwise, installations update the guide on a semiannual basis  if the installation is participating in the secure hold area program and  annually if it is not. However, even with the tools DOD makes available to  DOD personnel, shippers, and carriers, some carriers of arms,  ammunition, and explosives shipments are not able to gain access to  secure hold areas.
To find examples of instances where carriers were not provided secure  hold or assisted with finding alternate locations, we examined  descriptions reported in DOD’s Defense Transportation Tracking System  Emergency Response Reports. Following are examples of instances in  which DOD installations did not provide access to a secure hold area to  carriers transporting sensitive and classified HAZMAT:
A commercial carrier (i.e., a truck) transporting a shipment of  ammunition, explosives, and fireworks arrived at its final destination  point after normal working hours and was denied access to the  installation. DOD personnel at the final destination point directed the  carrier to another DOD installation for secure hold, but no one at that  installation answered the carrier’s calls requesting secure hold for the  night. Despite the carrier’s efforts to inform DOD personnel of the  security requirements for arms, ammunition, and explosives  shipments, the carrier was denied secure hold for the shipment and  spent the night in his truck with the shipment in an empty parking lot  near the highway. According to the Defense Transportation  Regulation, temporary parking for certain arms, ammunition, and  explosive shipments should be conducted at DOD-approved or  commercially owned secure holding facilities.
A DOD installation denied a commercial carrier access to a secure  hold area for a shipment of thousands of pounds of aircraft flares and  directed the carrier to park at a nearby major retail store parking lot.  DOD personnel told the Surface Deployment and Distribution  Command Operations Center that they regularly send carriers arriving  after hours to this retail store or a nearby rest area. Parking arms,  ammunition, and explosives at either location may be inconsistent  with DOD guidance.
DOD personnel at a secure hold installation instructed a commercial  carrier of a small-arms and parts shipment to arrive before the  installation closed because they would not accept after-hours  shipments. Furthermore, DOD personnel explained that the  installation was located in an unsafe neighborhood and advised the  carrier to park in a safe public parking lot away from the installation if  arriving after hours. Observing that the shipment would arrive after  hours, the carrier decided to spend the night in his truck with the  shipment parked at a public truck stop near the interstate highway.  The Defense Transportation Regulation indicates that personnel at  the DOD installation should assist the commercial carrier in identifying  another location that could provide secure hold.
According to the Defense Transportation Regulation, when commercial  carriers experience challenges gaining access to a secure hold area, the  carrier or DOD installation personnel can contact the Surface Deployment  and Distribution Command for assistance. According to officials,  Operations Center personnel are to attempt to resolve the issue by  referring to relevant regulations such as the Defense Transportation  Regulation, DOD Manual 5100.76-M (Physical Security of Sensitive  Conventional Arms, Ammunition, and Explosives), or rerouting the  shipment to another DOD location that can provide secure hold for the  shipment. However, if the installation and Operations Center personnel  cannot resolve the issue and grant carriers access to the secure hold  area, Operations Center personnel are to generate an Emergency  Response Report to document the actions taken by both parties and store  those reports in the Defense Transportation Tracking System. According  to the Surface Deployment and Distribution Command officials,  Operations Center personnel forward the Emergency Response Reports  to military-service representatives through an ad hoc process. However,  according to the officials, no further corrective action is required by those  representatives. As an example, during our visit the Operations Center  personnel demonstrated several examples of recent incidents where they  generated an Emergency Response Report as a result of DOD  installation personnel denying a carrier access to a secure hold area or  not assisting them in locating the nearest alternate means to secure those  shipments.
While the Surface Deployment and Distribution Command’s Emergency  Response Reports document installation and carrier issues gaining  access to secure hold areas at some DOD installations, according to  Surface Deployment and Distribution Command officials they lack  authority to change or require corrective actions to installation access  policies. According to these officials, such actions would be taken by the  military services or individual installation commanders. However, officials  told us that there is no process within the installations’ commands—which  set installation access policies—that requires them to follow up on  Emergency Response Reports to identify needed improvements or  recommend any corresponding corrective action at installations identified  in the reports. However, the Office of Management and Budget’s  Management’s Responsibility for Internal Control provides that  management is responsible for establishing and maintaining internal  control to achieve objectives such as compliance with applicable laws and  regulations. It further notes that agencies and individual federal managers  must take systematic and proactive measures to, among other things,  assess the adequacy of internal control in federal programs and  operations, identify needed improvements, and take corresponding  corrective action. Without such a process, DOD may not be able to  minimize the time that sensitive arms, ammunition, and explosives  shipments spend in public areas.
section_title: DOT Safety Measurement System Used by DOD to Evaluate Transportation Protective Service Carriers Lacks Sufficient Information to Reliably Compare Safety Performance Across Carriers
paragraphs: To ensure the safety and security of DOD’s shipments of sensitive arms,  ammunition, explosives, and classified shipments, DOD established a  Transportation Protective Services program as part of the Surface  Deployment and Distribution Command. Among other requirements to  participate in the program, commercial carriers providing certain services  must meet safety performance thresholds defined in DOD guidance using  scores from DOT’s Compliance, Safety, Accountability program, which is  managed by DOT’s Federal Motor Carrier Safety Administration.  Specifically, DOD uses the Federal Motor Carrier Safety Administration’s  Safety Measurement System scores—one component of the Compliance,  Safety, Accountability program—to determine which carriers are eligible  to participate in the department’s Transportation Protective Services  program. The Safety Measurement System within the Compliance,  Safety, Accountability program is a data-driven approach for identifying  carriers at risk of presenting a safety hazard or causing a crash. Safety  Measurement System data comprise information collected during  roadside inspections and from reported crashes to calculate scores  across seven categories that quantify a carrier’s safety performance  relative to that of other carriers. Specifically, the categories are: unsafe  driving, crash indicator, hours of service compliance, driver fitness,  controlled substances/alcohol, vehicle maintenance, and HAZMAT  compliance.violation rates in each of these categories for each commercial carrier  and then compares these rates to other carriers.
The Federal Motor Carrier Safety Administration calculates  DOT uses the Safety Measurement System scores to, among other  things, establish safety performance thresholds for carriers. For example,  for HAZMAT commercial carriers, DOT establishes a threshold score of  60 or lower (lower scores are better) in each of three categories: unsafe  driving, crash indicator, and hours-of-service compliance. DOT’s Federal  Motor Carrier Safety Administration identifies carriers who score above  the threshold as those posing the greatest safety risk. The Federal Motor  Carrier Safety Administration can then intervene to focus on specific  safety behaviors. The Federal Motor Carrier Safety Administration  intervention actions include sending warning letters, conducting on- and  off-site investigations, fines, or placing the carrier out of service.
DOD uses DOT’s Safety Measurement System scores to determine  whether commercial carriers are eligible for transporting HAZMAT under  the department’s Transportation Protective Services program. For all but  one of the seven Safety Measurement System categories, DOD requires  that commercial carriers seeking to provide certain Transportation  Protective Services meet DOT’s established HAZMAT carrier thresholds.  For compliance with the Safety Measurement System HAZMAT  regulations category, however, DOT establishes a threshold score no  higher than 80 for commercial carriers. In contrast, DOD requires a more- stringent score of 75. At the time of our review, only 53 of the over  400,000 commercial carriers in the United States had been selected to  participate in the Transportation Protective Services program.
In February 2014, we found that the Federal Motor Carrier Safety  Administration faces challenges in reliably assessing safety risk for the  majority of carriers. Among other things, most carriers lack sufficient  safety performance data to ensure that Federal Motor Carrier Safety  Administration can reliably compare them with other carriers using Safety  Measurement System scores. Basing an assessment of a carrier’s safety  performance on limited data may misrepresent the safety status of  carriers, particularly those without sufficient data from which to reliably  draw such a conclusion. In addition, previous evaluations of the Safety  Measurement System have focused on estimating the correlations  between crash risk and regulatory violation rates and Safety  Measurement System scores. These evaluations have found mixed  evidence that Safety Measurement System scores predict crash risk with  a high degree of precision for specific carriers or groups of carriers. As we  found, according to the Federal Motor Carrier Safety Administration’s own  methodology, the Safety Measurement System is intended to prioritize  intervention resources, identify and monitor carrier safety problems, and  support the safety fitness determination process.Carrier Safety Administration also includes a disclaimer with the publicly  released Safety Measurement System scores stating that the data are  intended for agency and law-enforcement purposes, and readers should  not draw safety conclusions about a carrier’s safety condition based on  the Safety Measurement System score, but rather the carrier’s official  safety rating. Due to ongoing litigation related to the Compliance, Safety,   The Federal Motor  Accountability program and the publication of Safety Measurement  System scores, we did not assess the potential effects or tradeoffs  resulting from the display or any public use of these scores. We  recommended that DOT improve the Compliance, Safety, Accountability  program by revising the Safety Measurement System methodology to  better account for limitations in drawing comparisons of safety  performance information across carriers; and in doing so, conduct a  formal analysis that specifically identifies, among other things, the  limitations in the data used to calculate Safety Measurement System  scores including variability in the carrier population and the quality and  quantity of data available for carrier safety performance assessments.  According to federal internal control standards, for an entity to run and  control its operations, it must have relevant, reliable, and timely  communications, including operational data. Program managers need  operational data to determine whether they are meeting their agencies’  goals for accountability, and effective and efficient use of resources.
DOT agreed to consider our February 2014 recommendations, but  expressed what it described as significant and substantive disagreements  with some aspects of our analysis and conclusions. To the extent that  DOT makes changes to the Safety Measurement System methodology,  this could also affect how DOD uses the information to evaluate  Transportation Protective Services carriers’ safety performance because  of the underlying data reliability concerns with the Compliance, Safety,  Accountability program’s Safety Measurement System data.
section_title: Conclusions
paragraphs: The complex framework governing the handling, labeling, and packaging  of DOD’s HAZMAT shipments exists to ensure the safe, timely, and cost- effective handling of these materials, but its complexity creates  challenges as shippers, carriers, and receivers implement the various  statutes and regulations of that framework. The distributed nature of this  framework—policies and procedures drawn from various organizations,  varying by class of HAZMAT and mode of transportation, and executed  by multiple players—creates conditions under which mistakes can be  made, particularly regarding pre-transportation functions (e.g., packaging  and labeling). While DOD has issued regulations and other guidance  regarding the handling of HAZMAT, it lacks adequate internal controls to  help ensure that its actions are consistent with those regulations and  guidance. Furthermore, the department lacks a clear understanding of  why these pre-transportation mistakes keep occurring. Absent a better  understanding of the root causes for these mistakes, the department will  be unable to identify corrective actions to better ensure the safe, timely,  and cost-effective transportation of its HAZMAT shipments. Moreover,  absent a department-wide process to identify necessary corrective action  to ensure that DOD installations provide access to secure hold, there is  no assurance that the installations will not repeatedly deny access to the  secure hold area for HAZMAT shipments or fail to assist carriers in finding  alternative means to secure those shipments. While the relative scale of  these incidents is fairly small, the nature of HAZMAT shipments is such  that the risk to public safety as well as the potential impact of cost and  timeliness should be minimized to the greatest extent practicable. DOD  uses Safety Measurement System scores to determine safety  performance of its Transportation Protective Services carriers. However,  both our February 2014 report and the Federal Motor Carrier Safety  Administration state that these scores should not be used to draw safety  conclusions about a carrier’s safety condition. As a result, DOD may be  determining which carriers should be eligible for the Transportation  Protective Services program using the Compliance, Safety,  Accountability’s Safety Measurement System that, for many carriers,  lacks sufficient information to reliably assess carriers’ safety performance.
section_title: Recommendations for Executive Action
paragraphs: To improve DOD’s compliance with HAZMAT regulations and other  guidance and potentially reduce shipment delays, we recommend that the  Secretary of Defense, in coordination with the Chairman of the Joint  Chiefs of Staff, direct the Under Secretary of Defense for Acquisition,  Technology and Logistics, in collaboration with the military departments  and TRANSCOM, to identify the root causes of improper documentation  and packaging of HAZMAT throughout the DOD transportation system,  identify any needed corrective actions, and develop an action plan with  associated milestones to implement those corrective actions.
To minimize the time sensitive arms, ammunition, and explosives  shipments spend in public areas, we recommend that the Secretary of  Defense, in coordination with the Chairman of the Joint Chiefs of Staff,  direct the Secretaries of the military departments, in collaboration with  TRANSCOM, to establish a process to identify and implement the  necessary corrective actions to ensure that DOD installations identified by  Surface Deployment and Distribution Command’s Emergency Response  Reports provide secure hold for sensitive shipments or assist them in  locating the nearest alternate means to secure those shipments.
To better ensure the safety and security of DOD’s shipments of sensitive  arms, ammunition, and explosives, we recommend that the Secretary of  Defense, in coordination with the Chairman of the Joint Chiefs of Staff,  direct TRANSCOM to examine the data limitations of the DOT Federal  Motor Carrier Safety Administration’s Safety Measurement System raised  in our February 2014 report on modifying DOT’s Compliance, Safety, and  Accountability program and determine what changes, if any, should be  made to the process used by DOD to decide HAZMAT carrier eligibility  and evaluate performance for the Transportation Protective Services  program.
section_title: Agency Comments and Our Evaluation
paragraphs: We provided a draft of our report to DOD and DOT for review.  In written  comments, DOD partially concurred with our first recommendation and  fully concurred with our second and third recommendations. DOD’s  written comments are reprinted in their entirety in appendix II. DOD and  DOT provided technical comments, which we have incorporated  throughout our report as appropriate.
DOD partially concurred with our first recommendation that the Secretary  of Defense, in coordination with the Chairman of the Joint Chiefs of Staff,  direct TRANSCOM, in collaboration with the Secretaries of the military  departments, to identify the root causes of improper documentation and  packaging of HAZMAT throughout the DOD transportation system,  identify any needed corrective actions, and develop an action plan with  associated milestones to implement those corrective actions. DOD  agreed to conduct the analysis we recommended, but stated that the  Under Secretary of Defense for Acquisition, Technology, and Logistics  rather than TRANSCOM would lead this analysis. DOD explained that,  because of the myriad of issues to be addressed, including training and  Transportation and Supply Discrepancy Reports, the Under Secretary of  Defense for Acquisition, Technology, and Logistics, not TRANSCOM, is  the proper organization to lead this analysis. We agree and have  amended our first recommendation accordingly.
DOD concurred with our second recommendation that the Secretary of  Defense, in coordination with the Chairman of the Joint Chiefs of Staff,  direct the Secretaries of the military departments, in collaboration with  TRANSCOM, to establish a process to identify and implement the  necessary corrective actions to ensure that DOD installations identified by  Surface Deployment and Distribution Command’s Emergency Response  Reports provide secure hold for sensitive shipments or assist them in  locating the nearest alternate means to secure those shipments.  Specifically, DOD stated that the Under Secretary of Defense for  Intelligence reissued Department of Defense Instruction 5100.76. DOD  also noted that the Under Secretary of Defense for Acquisition,  Technology and Logistics will work with the Under Secretary of Defense  (Intelligence), TRANSCOM, and the military departments to develop  corrective actions and operating methods geared toward eliminating  secure-hold denials. We agree that these actions, if fully implemented,  would address our recommendation.
DOD concurred with our third recommendation that the Secretary of  Defense, in coordination with the Chairman of the Joint Chiefs of Staff,  direct TRANSCOM to examine the data limitations of the DOT Federal  Motor Carrier Safety Administration’s Safety Measurement System raised  in our February 2014 report on modifying DOT’s Compliance, Safety, and  Accountability program and determine what changes, if any, should be  made to the process used by DOD to decide HAZMAT carrier eligibility  and evaluate performance for the Transportation Protective Services  program. However, DOD did not identify any specific steps it planned to  take to address our recommendation.
We are sending copies of this report to the appropriate congressional  committees and to the Secretary of Defense and the Secretary of  Transportation. The report also is available at no charge on GAO’s  website at http://www.gao.gov.
If you or your staff have any questions about this report, please contact  me at (202) 512-5431 or russellc@gao.gov. Contact points for our Offices  of Congressional Relations and Public Affairs may be found on the last  page of this report. Key contributors to this report are listed in appendix  III.
section_title: Appendix I: Scope and Methodology
paragraphs: To examine the statutes, regulations, guidance, policies, and procedures  that govern the Department of Defense’s (DOD) handling, labeling, and  packaging of hazardous material (HAZMAT) shipments to support military  operations, we reviewed the Hazardous Materials Transportation Act, as  amended; regulations issued by the Department of Transportation  (DOT), including the Hazardous Materials Regulation in Title 49 of the  Code of Federal Regulations; relevant sections of DOD’s Defense  Transportation Regulation, Joint Staff guidance, including Joint  Publication 4-01, The Defense Transportation System; and international  standards for the transport of HAZMAT. To better understand the  statutes, regulations, guidance, policies, and procedures that govern  DOD’s handling, labeling, and packaging of HAZMAT shipments to  support military operations, several members of the audit team completed  a 2-day DOD-sponsored course on HAZMAT that covered the above- mentioned areas and passed a comprehensive exam at the end of the  course demonstrating their understanding and knowledge of those topics.  To corroborate our understanding of this framework, we interviewed  officials from the Office of the Deputy Assistant Secretary of Defense for  Transportation Policy, Office of the Deputy Assistant Secretary of  Defense for Supply Chain Integration, the U.S. Transportation Command  (TRANSCOM), and DOT’s Pipeline and Hazardous Materials Safety  Administration. To understand DOD-specific requirements for transporting  HAZMAT shipments, we reviewed DOT’s Hazardous Materials  Regulations and DOD’s Defense Transportation Regulation and  interviewed officials from TRANSCOM—specifically, officials from the  Surface Deployment and Distribution Command, which is the Army  service component command of TRANSCOM that plans, transports, and  tracks DOD shipments.
To examine the extent to which DOD faces any challenges in  implementing its policies and procedures for transporting HAZMAT in a  safe, timely, and cost-effective manner, we selected and visited several  DOD locations involved in the transport of HAZMAT, including the U.S.  Defense Supply and Distribution Center (Richmond, Virginia);  TRANSCOM’s Surface Deployment and Distribution Command; and two  of DOD’s five major aerial ports: Dover Air Force Base (Dover, Delaware)  and Norfolk Naval Base (Norfolk, Virginia). Additionally, we interviewed  officials from another major aerial port—Travis Air Force Base (Fairfield,  California). We also visited Aberdeen Proving Ground (Aberdeen,  Maryland) to review the transport of arms, ammunitions, and explosives,  and to visit a secure hold location for that type of HAZMAT. We selected  these locations because they provided a cross section of the various  modes of transportation and hazardous-material classes. We also  selected these locations because they provided us with information on the  various central locations through which DOD transports these materials.  We focused our review on surface and air modes of transport—on  surface transport because most individual shipments are transported by  highway (94 percent of all shipments in fiscal year 2013) and on air  transport because that mode generally has more-restrictive requirements,  for example the quantity of certain HAZMAT (like acetic acid, class 8  HAZMAT) allowed on passenger air transport is lower than in other  modes. We reviewed data from TRANSCOM’s Global Air Transportation  Execution System for 5 fiscal years (fiscal years 2009 through 2013) and  the Defense Transportation Tracking System for fiscal years 2012 and  2013 to analyze records related to pretransportation and transportation  functions (e.g., handling, labeling, and packaging activities and the  transport of HAZMAT in commerce to the final destination point),  respectively. We compared data from those records with requirements in  the Defense Transportation Regulation. We found that the data we  examined were sufficiently reliable for identifying challenges and the  extent to which they affect the transport of HAZMAT.
We examined sections of the Hazardous Materials Regulations and the  Defense Transportation Regulation related to documenting and  packaging HAZMAT and to ensuring the secure hold of sensitive and  high-risk HAZMAT at DOD installations. We compared those sections  with records we examined related to pretransportation and transportation  functions (e.g., handling, labeling, and packaging activities and the  transport of HAZMAT in commerce to the final destination point).  Specifically, we reviewed fiscal years 2009 to 2013 records from  TRANSCOM’s Air Mobility Command’s Global Air Transportation  Execution System database, which is the aerial port operations and  management information system designed to support automated  shipments and passenger processing. We also reviewed data from fiscal  year 2012 and 2013 from the Emergency Response Reports provided  from the Defense Transportation Tracking System, part of TRANSCOM’s  Surface Deployment and Distribution Command, which catalogs  information involving shipments of arms, ammunition and explosives, and  other sensitive cargo. We found that the data we examined were  sufficiently reliable to identify secure-hold access issues that had been  reported. We reviewed records from DOT’s Federal Motor Carrier Safety  Administration to understand the Compliance Safety and Accountability  systems and how the safety scores generated by the system are used to  evaluate the Transportation Protective Services’ 53 carriers that transport  DOD’s sensitive arms, ammunition, and explosives shipments. To  corroborate our understanding of the documents and data we analyzed,  we interviewed officials from the Office of the Secretary of Defense; the  Office of the Deputy Assistant Secretary of Defense for Transportation  Policy; the Defense Logistics Agency; the Army, the Air Force, the Navy,  the Marine Corps; and DOT’s Pipeline and Hazardous Materials Safety  Administration.
We visited or contacted officials from the following DOD and DOT  organizations during our review:
Defense Logistics Agency, Aviation Branch, Richmond, Virginia;
Defense Logistics Agency, U.S. Defense Supply and Distribution  Center, Richmond, Virginia;
Headquarters, Defense Logistics Agency, Fort Belvoir, Virginia;
Headquarters, Department of the Army, Pentagon, Arlington, Virginia;
Headquarters, U.S. Marine Corps, Naval Annex, Arlington, Virginia;
Office of the Under Secretary of Defense (Acquisition, Technology  and Logistics), Office of the Deputy Assistant Secretary of Defense  (Transportation Policy), Mark Center, Alexandria, Virginia;
Office of the Under Secretary of Defense (Acquisition, Technology  and Logistics), Office of the Deputy Assistant Secretary of Defense  (Supply Chain Integration), Mark Center, Alexandria, Virginia;
U.S. Air Force, Dover Air Force Base, Dover, Delaware;
U.S. Air Force, Travis Air Force Base, Fairfield, California;
U.S. Air Force, Headquarters Air Materiel Command, Wright- Patterson Air Force Base, Dayton, Ohio;
U.S. Army Operations Center, Pentagon, Arlington, Virginia;
U.S. Army, Public Health Command, Army Institute of Public Health,  Aberdeen Proving Ground, Maryland;
U.S. Army, Surface Deployment and Distribution Command, 596th  Transportation Brigade, Sunny Point, North Carolina;
U.S. Army, Surface Deployment and Distribution Command, 597th  Transportation Brigade, Fort Eustis, Virginia;
U.S. Army Sustainment Command, Rock Island Arsenal, Rock Island,  Illinois;
U.S. Army Medical Command, Fort Sam Houston, San Antonio,
U.S. Army, Medical Research Institute of Chemical Defense,  Aberdeen Proving Ground, Aberdeen, Maryland;
U.S. Navy, Naval Station Norfolk, Norfolk, Virginia;
U.S. Transportation Command, Scott Air Force Base, Illinois;
Air Mobility Command;
Military Sealift Command;
Surface Deployment and Distribution Command;  o  Defense Transportation Tracking System Office; and
U.S. Department of Transportation, Washington, D.C.
We conducted this performance audit from April 2013 to May 2014 in  accordance with generally accepted government auditing standards.  Those standards require that we plan and perform the audit to obtain  sufficient, appropriate evidence to provide a reasonable basis for our  findings and conclusions based on our audit objectives. We believe that  the evidence obtained provides a reasonable basis for our findings and  conclusions based on our audit objectives.
section_title: Appendix II: Comments from the Department of Defense
section_title: Appendix III: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Staff Acknowledgments
paragraphs: In addition to the contact named above, James A. Reynolds, Assistant  Director; Adam Anguiano; Alfonso Garcia; Brandon Jones; Mae Jones;  Oscar W. Mardis; Terry Richardson; and Michael Shaughnessy made key  contributions to this report.