Publicly Released: March 25, 2020
The objective of this audit was to determine whether the DoD protected arms, ammunition, and explosives (AA&E) transported in the United States by commercial ground carriers in accordance with the Defense Transportation Regulation (DTR).
The DTR provides the overall requirements for transportation within the DoD, including the transportation and secure hold of AA&E. To transport AA&E in the United States, the DoD relies on commercial trucking, rail, and small package couriers.
When shipping AA&E, the DTR requires the DoD to include safeguards, such as satellite tracking of the carrier vehicle. The Military Surface Deployment and Distribution Command (SDDC), an Army subordinate command to the U.S. Transportation Command (USTRANSCOM), uses the Defense Transportation Tracking System (DTTS) to monitor all commercial trucking carriers transporting AA&E within the United States.
DoD officials and commercial carriers are required to report incidents that occur with AA&E shipments, including accident reports, shipments that do not appear in DTTS (“not‑in‑system” shipments), and reports of denial of entry onto installations to deliver AA&E shipments (known as secure hold denials). Secure hold areas are areas of a military installation specifically designated for securely storing AA&E shipments.
The DoD and its commercial carriers transported 107,625 AA&E ground shipments (103,853 by truck and 3,772 by rail) from October 2016 through March 2019. Based on our review of 16 accident reports, 20,426 not‑in‑system shipment records, and 9 reports of secure hold denials, we determined that the DoD and the commercial carriers did not always transport AA&E by ground in accordance with the DTR. Specifically, the DoD did not properly:
• pack at least two AA&E ground shipments, as required by the DTR and DoD Component criteria for AA&E shipments.
• verify that information about the contents of the AA&E shipment was in the tracking system for 20,426 of 103,853 ground shipments made by truck, as required by the DTR. The SDDC categorized these 20,426 shipments as not‑in‑system shipments. In addition, all 3,772 AA&E rail shipments and all small package shipments of arms and ammunition were not tracked by SDDC systems.
• provide commercial carriers with access to installations so the carrier could deliver nine AA&E truck shipments to the installation, as required by DoD guidance.
• follow up on 12 of the 33 SDDC safety investigation recommendations made in 13 transit accident reports because the SDDC lacked authority to implement and adjudicate the recommendations for non-SDDC organizations.
As a result of these specific packing, tracking, and delivery problems and an accident in 2017, the public was unnecessarily exposed to AA&E that was stolen, damaged, exploded, ignited, or spilled across public highways. Any mishap with AA&E can be catastrophic. There were also safety risks from trucks loaded with AA&E that were parked at non-secure local truck stops for extended periods or on the street to wait until AA&E cargo could be delivered to its destination. AA&E, when stolen, gives criminals the opportunity to use military grade arms for illegal activities. In addition, when AA&E is stolen, damaged, or exploded, the DoD must replace that ammunition, which costs time and money and can hamper operations if the AA&E is not available when needed. Furthermore, without the ability for the SDDC to hold the Military Services accountable for not following the DTR or for implementing improvements to Military Service processes for AA&E transportation and secure hold, the SDDC is hampered in its ability to mitigate these types of occurrences in the future.
We recommend that the Assistant Secretary of Defense for Sustainment, in coordination with USTRANSCOM and the Military Services, give the SDDC the authority to enforce the Military Services’ compliance with:
• the DTR and hold Military Service officials accountable for not complying with the regulations, and for not transmitting bills of lading to the DTTS; and
• SDDC accident investigation recommendations through a system of draft recommendations, command response, SDDC evaluation of those responses, and adjustment of the SDDC recommendations.
We also recommend that the Assistant Secretary of Defense for Sustainment, in coordination with USTRANSCOM and the Military Services:
• develop and implement a methodology or controls to prevent the Military Services from allowing AA&E shipments to leave a military installation until officials confirm that the bill of lading is transmitted to DTTS for tracking, and
• evaluate creating a centralized tracking system to track rail shipments of AA&E and implement that tracking system, if appropriate.
We recommend that the Military Departments, in coordination with the SDDC Commander, develop and implement training for secure hold requirements at military installations and direct the base commanders with secure hold areas to implement the training with appropriate staff.
We recommend that the USTRANSCOM Commander, in coordination with the Military Services, update the DTR to require installations receiving AA&E to send a receipt confirmation of the report of shipment and notify those who work at the installation’s delivery access points that there is an incoming shipment of AA&E to reduce the risk of a secure hold denial.
Management Comments and Our Response
Responding for the Assistant Secretary of Defense for Sustainment, the Acting Principal Deputy Assistant Secretary of Defense for Sustainment disagreed with the recommendations to give the SDDC the authority to enforce the Military Services’ compliance with the DTR and implement a system of accident investigation recommendations, command response, and SDDC evaluation of those responses. The Acting Principal Deputy stated that there is no requirement for the SDDC to assume an enforcement role, and the SDDC currently provides daily reports to the Military Services. The Acting Principal Deputy also stated that the current process enables SDDC investigation of vehicle accidents and allows the Military Services to address any issues identified.
The Acting Principal Deputy’s comments did not address the specifics of the recommendation; therefore, the recommendation is unresolved. DoD regulations clearly entrust the Office of the Assistant Secretary of Defense for Sustainment with AA&E oversight responsibility. DoD Instruction 5100.76 states that the Assistant Secretary has the responsibility to perform “continuous program and policy oversight . . . to ensure protection of AA&E within the DoD.” While the current process may allow the Military Services to address issues identified in an SDDC accident investigation, the process does not ensure proper vetting and resolution of SDDC accident recommendations.
The Acting Principal Deputy partially agreed with the recommendation to develop and implement a methodology or controls to prevent AA&E shipments from leaving a military installation until officials confirm that the bill of lading is transmitted to DTTS for tracking. The Acting Principal Deputy stated that the Military Services and commercial shippers have the responsibility to implement the DTR and ensure compliance. The Acting Principal Deputy further stated that the SDDC is actively addressing not‑in‑system cases by providing visibility to the Military Services for review and action, resulting in a downward trend in the number of not‑in‑system shipments over the past 3 years.
The Acting Principal Deputy’s comments partially addressed the recommendation; therefore, the recommendation is unresolved. While the Acting Principal Deputy stated that there was a downward trend over the past 3 years, he did not provide documentation to support his statement. In addition, during our audit the SDDC provided us not-in-system data from October 2016 through February 2019, which showed that not‑in‑system shipments stayed the same or slightly increased during that 3-year period.
The Acting Principal Deputy agreed with the recommendation to evaluate creating a centralized tracking system to track AA&E rail shipments. Therefore, the recommendation is resolved but will remain open. We will close the recommendation once we verify that the Assistant Secretary has completed the analysis of the tangible benefits of a centralized rail tracking system and we review the analysis.
Responding for the SDDC Commander, the USTRANSCOM Chief of Staff did not agree with a draft report recommendation that the SDDC develop training for secure hold requirements at military installations. The Chief of Staff noted that DoD regulations task the Military Services with providing secure hold requirements training to installations.
Based on the Chief of Staff’s comments, we revised and redirected this recommendation in the final report to each of the Military Departments, as well as to the SDDC. In the revised recommendation, we request that the SDDC serve a coordination role for the Military Services in implementing consistent secure hold policies.
The Chief of Staff agreed with recommendations that USTRANSCOM, in coordination with the Military Services, update the DTR to require installations receiving AA&E to send a receipt confirmation of the report of shipment and notify those who work at the installation’s delivery access points that there is an incoming shipment of AA&E to reduce the risk of a secure hold denial. The USTRANSCOM Chief of Staff stated that the DTR would be updated by September 1, 2020.
The Chief of Staff’s comments addressed the recommendations; therefore, the recommendations are resolved but will remain open. We will close the recommendations once we verify that the DTR change has been made.
We request that the Assistant Secretary of Defense for Sustainment and the SDDC Commander provide additional comments in response to unresolved report recommendations.
This report is the product of Proj. No. D2019-D000RK-0114.000