Defense Transportation: DOD Needs to Take Actions to Improve the Transportation of Hazardous Material Shipments
What GAO Found
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.
Existing Statutory and Regulatory Elements That Department of Defense Incorporated into the Defense Transportation Regulation and Other Guidance
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.
Why GAO Did This Study
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.
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.
Recommendations for Executive Action
|Department of Defense||To minimize the time sensitive arms, ammunition, and explosives shipments spend in public areas, the Secretary of Defense, in coordination with the Chairman of the Joint Chiefs of Staff, should 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.||
According to SDDC officials, the Defense Transportation Tracking System (DTTS) started tracking and reporting secure hold denial incidents based on the recommendation we made in our report. SDDC and DTTS reports indicated that for fiscal years 2012 and 2013, 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. According to SDDC officials, the numbers of trucks parked in unauthorized locations have dropped significantly due to DOD's response to our GAO-14-375 report. DTTS emergency reports now track secured hold denials as a separate item on their incident reports. Thus, SDDC officials stated that they can identify such secure hold denial issues and take corrective actions.
|Department of Defense||To improve DOD's compliance with HAZMAT regulations and other guidance and potentially reduce shipment delays, the Secretary of Defense, in coordination with the Chairman of the Joint Chiefs of Staff, should direct the Under Secretary of Defense for Acquisition, Technology and Logistics, in collaboration with the military departments and the U.S. Transportation Command (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 improve the transportation of hazardous material shipments, DOD published a Plan of Actions and Milestone with at least 16 new initiatives with milestones in order to address their significant problems with documentation and packaging of HAZMATs. As of March 2016 DOD had implemented seventy percent of these initiatives that are helping DOD identify root causes for improper packaging and documentation issues as well to develop a corrective action plan.
|Department of Defense||To better ensure the safety and security of DOD's shipments of sensitive arms, ammunition, and explosives, the Secretary of Defense, in coordination with the Chairman of the Joint Chiefs of Staff, should 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.||
According to DOD officials, DOD has examined the DOT data limitations as reported by GAO in 2014 and has determined that the DOD TPS program guidance is sufficient in describing carrier safety requirements. The DOD regularly evaluates carrier safety performance for continued participation in the TPS program through the Military Surface Deployment and Distribution Command's (SDDC)Transportation Safety and Security program where a contractor performs reviews, at both carrier facilities and while shipments are in-transit, of carrier and driver safety performance. DOD has placed less reliance on DOT scores for evaluating overall carrier safety performance as a result of the 2014 GAO report, which was critical of the DoT scoring system in a number of areas, to include a finding that the majority of regulations used to calculate the safety scores are not violated often enough to strongly associate them with crash risk for individual carriers.