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The Army Needs to Improve Controls Over Chemical Surety Materials

DODIG-2017-090

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June 7, 2017 — Objective

We determined whether the DoD had effective controls over chemical surety materials1 in the possession or under the control of the Army and DoD contractors. Specifically, we evaluated accountability and access controls over chemical surety materials at the U.S. Army Pueblo Chemical Depot (Pueblo), U.S. Army Dugway Proving Ground (Dugway), and a contractor. We also evaluated whether the personnel properly documented the destruction of assembled chemical munitions at Pueblo and U.S. Army Deseret Chemical Depot (Deseret).

Findings

Army officials properly implemented accountability controls such as inventory management or documenting the destruction of the chemical munition stockpile stored at Pueblo and Deseret; however, Army and contractor personnel did not fully implement accountability controls over chemical surety materials stored at Dugway and a contractor’s facility. Specifically, Dugway and contractor officials did not conduct chemical agent inventories by primary container when one or more primary containers were stored in secondary containers.2 Under the current process in place at these facilities, the primary containers remained sealed within the secondary containers during inventories; therefore, custodians cannot identify and account for leaks, evaporation, or theft that may have occurred. Furthermore, Dugway officials did not immediately notify the chemical materials accountability officer of a 1.5-milliliter shortage of the chemical surety material sarin (GB) identified during an April 19, 2016, inventory nor did they properly document the results of that inventory.

In addition, the type of secondary containers used to store chemical surety materials varied at Dugway and the contractor’s facility, and each location used different materials to seal secondary containers. Specifically, Dugway used stainless steel cylinders and ammunition cans sealed with tamper-evident seals; and the contractor used re-sealable plastic containers sealed with tape, which provides no assurance that only authorized personnel had access to chemical surety materials. The Commander, Dugway Proving Ground, also assigned one individual to serve as the accountable officer and primary agent custodian. Although we did not identify instances of fraud or theft during the audit, not segregating the accountable officer and primary agent custodian duties increases the risk of recordkeeping errors and theft.

Army and contractor personnel did not fully implement Army accountability controls because Dugway and the contractor standard operating procedures contradict the Army Regulation (AR) 50-6, “Chemical Surety,” July 28, 2008, requirement to conduct inventory by primary container. Although the proponents of DoD Instruction 5210.65, “Security Standards for Safeguarding Chemical Agents,” January 19, 2016, stated that they agreed with the practice of conducting inventories by sealed, secondary containers, they had not documented that in the Instruction. Army Inspector General personnel stated that they conducted chemical surety inspections based on the proponents’ agreed upon practice and not the AR 50-6 requirement. Additionally, DoD Instruction 5210.65 and AR 50-6 do not define minimum specifications for secondary containers and do not provide guidance on the appropriate segregation of duties over the accountability for chemical surety materials. Not fully implementing accountability controls and insufficient oversight and guidance increases the risk that Dugway and the contractor will not properly store and account for chemical surety materials.

In addition, personnel at Dugway, the contractor, and Pueblo did not consistently implement their respective chemical personnel reliability program (CPRP) requirements. Specifically, certifying officials did not always report prior drug use to reviewing officials; competent medical authorities did not always provide potentially disqualifying information to certifying officials; CPRP-certified individuals did not always self-report potentially disqualifying information in a timely manner; a certifying official at Pueblo did not properly refer an individual for medical evaluation after an alcohol-related incident; and officials did not always conduct personnel security investigations in a timely manner.

CPRP requirements were inconsistently implemented because chemical surety officers did not always provide effective oversight of the program. As a result, there was increased risk that those locations would not meet the purpose of the Army chemical surety program as stated in AR 50-6; which is to ensure that chemical agent operations are conducted in a safe, secure, and reliable manner.

Recommendations

We recommend that the Deputy Assistant Secretary of Defense for Chemical and Biological Defense revise DoD Instruction 5210.65 to provide clear guidance on appropriate segregation of duties and define acceptable inventory practices.

We recommend that the Deputy Chief of Staff, G-3/5/7, Headquarters Department of the Army coordinate with the Deputy Assistant Secretary of Defense for Chemical and Biological Defense to provide guidance on appropriate segregation of duties and revise AR 50-6 to align with the revision to DoD Instruction 5210.65 that defines acceptable inventory practices for Army and contractor facilities in possession of chemical surety materials. We also recommend that the U.S. Army Inspector General update chemical surety inspections to align with the revised DoD and Army guidance.

We recommend that the Commanding General, U.S. Army Materiel Command, and Commander, Dugway Proving Ground, require chemical material custodians to perform a 100-percent physical inventory of chemical agents, by primary container to establish a baseline of the chemical agent inventory before implementing any alternate inventory procedures; and update standard operating procedures to include any revised inventory requirements.

We also recommend that the Commander, Dugway Proving Ground, provide refresher training on reporting and resolving inventory discrepancies and establish adequate segregation of duties over the accountability of chemical surety material inventory.

We recommend that the Commanding General, U.S. Army Materiel Command; the Commander, Dugway Proving Ground; and the Commander, Pueblo Chemical Depot, implement additional internal controls to ensure the chemical surety officer provides effective oversight of compliance with Chemical Personnel Reliability Program requirements.

Management Comments and Our Response

The Deputy Assistant Secretary of Defense for Chemical and Biological Defense partially agreed with the recommendation; he agreed to revise DoD Instruction 5210.65 and did not agree to provide guidance on the appropriate segregation of duties. Therefore, the recommendation is unresolved. The Deputy Assistant Secretary of Defense for Chemical and Biological Defense should provide comments to the final report specifying the minimum standards for a secondary container and the types of seals required, and how the duties of the primary agent custodian and the accountable officer will be segregated. We request that the Deputy Assistant Secretary of Defense for Chemical and Biological Defense provide comments to the final report by July 7, 2017.

The Department of the Army, Deputy Chief of Staff, G-3/5/7, agreed with the recommendation to revise AR 50-6 to define acceptable inventory practices for Army and contractor facilities in possession of chemical surety materials. Therefore, the recommendation is resolved and will be closed when we review and verify the revised AR 50-6 that includes acceptable inventory practices for Army and contractor facilities in possession of chemical surety materials. The Department of the Army, Deputy Chief of Staff, G-3/5/7, did not agree with the recommendation to provide guidance on the appropriate segregation of duties; therefore, the recommendation is unresolved. The Department of the Army, Deputy Chief of Staff, G-3/5/7, should specify how the duties of the primary agent custodian and the accountable officer will be segregated. We request that the Department of the Army, Deputy Chief of Staff, G-3/5/7, provide comments to the final report by July 7, 2017.

The Principal Deputy Chief of Staff for Operations and Logistics, G-3/4, responding for the Commanding General, U.S. Army Materiel Command, agreed with the recommendations:

  • to conduct a 100-percent inventory by primary container to establish a baseline chemical agent inventory prior to implementing any alternate inventory procedures defined by the Deputy Assistant Secretary of Defense for Chemical and Biological Defense or the Department of the Army, Deputy Chief of Staff, G-3/5/7;
  • to ensure the contractor’s standard operating procedures are updated to include revised inventory procedures; and,
  • that the U.S. Army Materiel Command Chemical Surety officer performs periodic reviews of the contractor’s certifying official files to ensure chemical surety guidance is followed.

Therefore, the recommendations are resolved and will be closed when we verify that the contractor’s standard operating procedures have been updated to include the revised inventory procedures and we review the results of the contractor’s file review and laboratory certification.

Although the U.S. Army Inspector General did not agree with the recommendation to update chemical surety inspections to align with DoD Instruction 5210.65 and AR 50-6, his statement that he will modify the inspection methodology in response to changes in the DoD and Army standards addresses all specifics of the recommendation. Therefore, the recommendation is resolved and will be closed when we review the updated inspection methodology reflecting revisions to DoD Instruction 5210.65 and AR 50-6.

The Commander, Dugway Proving Ground, agreed with the recommendations to:

  • conduct a 100-percent inventory by primary container to establish a baseline chemical agent inventory prior to implementing any alternate inventory procedures defined by the Deputy Assistant Secretary of Defense for Chemical and Biological Defense or the Department of the Army, Deputy Chief of Staff, G-3/5/7;
  • update Dugway Proving Ground standard operating procedure, DP-0000-L-651 to comply with the updated inventory requirements;
  • provide refresher training on reporting and resolving inventory discrepancies; and
  • implement additional internal controls to ensure the chemical surety officer provides effective oversight.

Therefore, the recommendations are resolved and will be closed when we:

  • review the results of the 100-percent inventories conducted in June and December 2016;
  • verify that the standard operating procedure has been updated to comply with updated inventory requirements;
  • review documentation verifying that personnel with chemical agent accountability duties received refresher training; and
  • verify that Dugway Regulation 50-1 includes additions and changes in internal controls.

The Commander, Dugway Proving Ground, did not agree with the recommendation to ensure that segregation of duties over the accountability of chemical surety material inventory is maintained. Therefore, the recommendation is unresolved. The Commander, Dugway Proving Ground, should provide comments to the final report specifying how the segregation of duties over the accountability of chemical surety material inventory will be maintained. We request that the Commander, Dugway Proving Ground, provide comments to the final report by July 7, 2017.

The Commander, Pueblo Chemical Depot, agreed with the recommendation to develop and implement additional internal controls to ensure the chemical surety officer provides effective oversight. Therefore, the recommendation is resolved and will be closed when we verify that the internal controls have been updated.


 

 1 Chemical surety material is any neat (full-strength) or diluted chemical agent of which the quantity or concentration exceeds limits established by the Army.  See Appendix C of this report.

 2 A primary container is a vessel, ampule, cylinder, or other receptacle that holds a chemical agent.