This week's document: Level III Corrective Action Request for UNICOR Federal Prison Industries, INC
Document agency: Defense Contract Management Agency
Document date: April 6, 2010
Every Friday, POGO will strive to make one document available that we or others have obtained through the Freedom of Information Act (FOIA), especially documents that have not previously been posted online. Some of these documents will be more important than others, some may only be of historical interest— although relevance is in the eye of the beholder. POGO is doing this to highlight the importance of open government and FOIA throughout the year.
By ANDRE FRANCISCO
In May of last year, the Army recalled 44,000 combat helmets after the discovery of a paint problem led to tests that showed the helmets failed when hit with multiple gunshots from a specific angle. Inmates from a federal prison in Beaumont, Texas helped make the helmets while working for UNICOR Inc., also known as Federal Prison Industries, Inc., a wholly-owned government corporation. As of 2010, UNICOR employed nearly 16,000 inmates who received pay of 23 cents to $1.15 per hour, according to its website. UNICOR only sells products to the federal government, mostly to the Department of Defense.
This week's document offers more details about the problems at the UNICOR manufacturing site in Beaumont that made the recalled helmets and about the Level III corrective actions that the Defense Contract Management Agency (DCMA) asked UNICOR to make. The stakes were high as “the helmets associated with the contracts [examined by DCMA] are ‘Critical Safety Items,’” according to the corrective action request sent to UNICOR by DCMA.
The letter was sent in April of last year. It included a March 2010 DCMA audit report that detailed the evaluation of the quality management system at UNICOR’s Beaumont facility. The audit was conducted by a four-person team over the course of four days.
The review lists seven areas of major noncompliance and one minor area. Some of them dealt with issues like improper documentation or training manuals, but the more serious claims include numerous instances where nonconforming helmets were stored next to good helmets and where both good and nonconforming helmets were mislabeled.
The review also cites a failure to make previously identified changes “despite multiple internal audit findings regarding control of documents and control of nonconforming material.”
These problems led the DCMA to issue a Level III (out of four possible levels) corrective action request. A Level III request indicates a systemic problem as opposed to flaws with individual units. Level III and IV requests are rare compared to the issuance of less serious Level I and II requests.
A noncompliant quality management system does not necessarily directly mean there is shoddy workmanship (just as a compliant system does not guarantee there will be no shoddy workmanship), but it does make the production of defective products more likely and reduces the chances that defective products and the processes that lead to them will be identified.
Before the March 2010 DCMA audit and April 2010 corrective action request, suspicions were sparked in November 2009 when soldiers noticed paint peeling off of the helmets, according to a news report on Military.com. The Justice Department started investigating and recommended that the Army retest its helmets. The issues were serious enough to warrant a stop work order by the Army in February 2010. The recall of 44,000 Advanced Combat Helmets occurred in May 2010 after “tests revealed that they fail[ed] to provide the required level of ballistics protection.” It is not clear if the March DCMA audit report factored in to the Army’s recall decision.
UNICOR was criticized for not implementing recommended changes at another program it manages more recently. The Council of Prison Locals, a union for prison officers, criticized the Bureau of Prisons (BOP) for not implementing safety recommendations made by the Justice Department’s Office of Inspector General about an electronic waste recycling program run by UNICOR.
"It's unconscionable that BOP has yet to implement the inspector general's recommendations to ensure worker safety," Council of Prison Locals President Bryan Lowry said in a press release.
The DMCA report also mentioned what seems like a systemic problem with the program: “The environment in which UNICOR operates is unique and may be contributing to the challenges of developing, implementing, and sustaining a healthy Quality Management System.”
Though it’s unrelated to UNICOR, the Army has also recently had problems with a large amount of body armor being shipped to soldiers without being properly tested.
Andre Francisco is a POGO communications associate.
Image via The U.S. Army.