May 1, 2018 —
We determined whether Defense Logistics Agency (DLA) Disposition Services properly processed and disposed of equipment in Kuwait.
The DLA’s mission is to provide effective and efficient worldwide support to warfighters and other customers. As part of this support, the DLA offers equipment disposition, including equipment turn-in; reutilization, transfer, and donation; and sales. Reutilization, transfer, and donation of equipment saves the DoD substantial procurement and repair costs, and benefits the Military Services, Federal agencies, state and local governments, nonprofit agencies, and American taxpayers.
DLA Disposition Services sites dispose of all DoD-generated excess, surplus, foreign excess, and other personal property authorized for turn-in. DLA Disposition Services headquarters in Battle Creek, Michigan, develops and updates guidance and procedures for processing and disposing of equipment.
DLA Disposition Services Kuwait, located in DLA Disposition Services’ Central disposal region, provides services in Afghanistan, Bahrain, Kuwait, Qatar, and the United Arab Emirates. The DLA Disposition Services site at Camp Arifjan, Kuwait, is one of the largest DLA disposition sites in the world. The disposition process in Kuwait starts with a pre-receipt process, in which DLA Disposition Services Kuwait officials travel to the customer to preview equipment and ensure all required turn-in documents are prepared correctly. A DLA Disposition Services’ official provides an internal DLA Disposition Services reference number to the customer to schedule an appointment. The customer then turns in the equipment to DLA Disposition Services Kuwait during the scheduled appointment, and the equipment is either reutilized, scrapped, or demilitarized.
Because of hazards associated with the disposition process such as cuts, loss of eyes and limbs, and head injuries, DLA Disposition Services Kuwait officials must implement Occupational Safety and Health Program requirements. Specifically, DLA Instruction 6055.01 requires DLA Disposition Service Kuwait officials to report and track all hazards, conduct personal protective equipment assessments, and ensure that safe work practices are followed
We determined that DLA Disposition Services officials properly processed and disposed of equipment in Kuwait; however, improvements are necessary to mitigate life, health, and safety hazards. Specifically, DLA Disposition Services Kuwait officials did not consistently:
- ensure personnel responsible for disposing of equipment wore the required personal protective equipment; and
- conduct annual Job Hazard Analysis reviews and identify and develop Job Hazard Analyses for DLA Disposition Services officials as required by DLA guidance.
This occurred because the Director, DLA Disposition Services Directorate—Central did not ensure officials provided comprehensive oversight of employees and contractors’ adherence and implementation of safety requirements.
As a result, DLA Disposition Services Kuwait officials and Gulf Civilization General Trading contractors responsible for disposing of equipment in Kuwait are susceptible to significant injuries. For example, a contractor suffered temporary hearing loss and a cut finger during cutting operations. According to signs in the cutting area, safety gloves and respiratory mask are required within 45 feet of ongoing operations. DLA Disposition Services’ Kuwait officials did not specify whether the contractor was wearing proper personal protective equipment at the time the incident was reported. Yet, without proper personal protective equipment contractors in similar incidents are at increased risk of injuries. To prevent additional injuries from occurring, DLA Disposition Services Kuwait officials must increase oversight of contractors’ adherence to safety requirements to mitigate hazards.
In addition, DLA Disposition Services Kuwait officials established site-specific pre-receipt processes that resulted in equipment turn-in efficiencies, such as reduced backlog and processing times, but did not document this process. Failure to document site‑specific processes increases the risk of backlogs of equipment awaiting turn-in and longer processing times. For example, DLA Disposition Services Kuwait officials may not accept equipment that arrives without the proper documents and will either send the equipment back with the customer or hold it onsite until the customer provides the proper documentation, resulting in delays. In addition, if these processes are not documented, future rotations of DLA Disposition Services Kuwait officials may not continue these best practices.
We recommend that the Director, DLA Disposition Services Directorate—Central:
- establish a schedule to conduct inspections to ensure contract personnel wear proper personal protective equipment and report any nonconformance to the contracting officer;
- provide supervisors and employees Job Hazard Analyses for their respective areas of oversight; and
- create a Job Hazard Analysis for shredding operations.
In order to sustain current pre-receipt processes, we also recommend that the Director, DLS Disposition Services Directorate—Central document the pre-receipt process developed in Kuwait.
Management Actions Taken:
The Director, DLA Disposition Services Directorate—Central agreed with our recommendations and immediately initiated corrective actions. DLA Disposition Services Kuwait officials updated the contracting officer’s representative checklist to require contracting officer’s representatives to conduct daily inspections to identify whether contract personnel wear the proper personal protective equipment. The Director, DLA Disposition Services Directorate—Central provided supervisors and employees training on Job Hazard Analyses for their applicable areas of oversight. DLA Disposition Services’ officials also developed a Job Hazard Analysis for shredding operations. Additionally, DLA Disposition Services Kuwait officials documented the pre-receipt process developed in Kuwait. The actions taken are sufficient to close both recommendations.
This report is a result of Project No. D2017-D000JB-0194.000.