The Bureau of Alcohol, Tobacco, Firearms and Explosives’ and Federal
Bureau of Investigation’s Arson and Explosives Intelligence Databases

Audit Report 05-01
October 2004
Office of the Inspector General

Appendix IX

Office of the Inspector General, Audit Division
Analysis and Summary of Actions Necessary to Close the Report


In its September 27, 2004, response to the draft report, the Bureau of Alcohol, Tobacco, Firearms, and Explosives (ATF) indicated that it has established a Memorandum of Understanding (MOU) with all Bombing and Arson Tracking System (BATS) users that requires adherence to set standards. Additionally, the ATF has provided all users with a guide containing standards on how to populate the database with arson incidents and suspected misuse of explosives. Furthermore, the ATF said it will periodically review a statistical sample of the data contained within BATS to check for adherence to the requirements prescribed in the MOU.

In its September 23, 2004, response to the draft report, the Federal Bureau of Investigation (FBI) agreed with our conclusion that duplication of effort between the FBI and the ATF in compiling and disseminating data on explosives incidents results in confusion and inconsistency. However, despite the Attorney General's memo of August 11, 2004, which directed the Department to consolidate the arson and explosive incidents databases under the ATF, the FBI disagreed with recommendation 1, stating, "We disagree, however, with the OIG's recommendation in the first paragraph on page 37, that the databases of the FBI and BATFE should be consolidated under the BATFE." Additionally, the FBI commented on other issues in the report. These issues are addressed below:

Executive Summary. Our draft report stated that the FBI does not normally receive and record arson-only incidents. The FBI commented that the Uniform Crime Reporting Act of 1988, 28 U.S.C. 534, and 28 C.F.R. 0.85 (f) clarifies that the FBI is directed to compile criminal statistics (including arson statistics) from federal, state, and local agencies and operate a central clearinghouse for police statistics under the Uniform Crime Reporting Program. Additionally, the FBI commented that the FBI's Uniform Crime Report Program routinely shares arson statistics with the ATF. On the basis of the FBI's comments, we revised the Executive Summary to show that the Bomb Data Center (BDC), rather than the FBI as a whole, normally does not receive and record arson-only incidents.

Automated Incident Reporting System (AIRS). The FBI stated in its response that the COBRA system was implemented in 1998. In addition, the FBI said it had provided all of the more than 440 accredited bomb squads in the United States with a COBRA system with which they have had the ability to enter data directly into AIRS since 1999. We added the FBI's comments to the report.

The FBI also stated in its response that since AIRS is a direct entry system available to every bomb squad and the ATF's BATS is a pilot project available to only two departments, the Department should continue to use AIRS. However, the FBI's response also indicated that direct entry into AIRS is optional. In fact, we found that thousands of entries in AIRS were made by BDC and contract staff who transcribed data from hard copies submitted by contributing agencies. In addition, an October 1, 2004, FBI memorandum indicated that no data in the COBRA system was in the AIRS database yet, but that data would be converted and downloaded into AIRS over the next 60 days.

Finally, the FBI commented on our statement that, "On August 19, 2004, FBI officials indicated they did not want to include subject and suspect data, or data related to juveniles," in a consolidated database. The FBI does not feel the Internet is an appropriately secure means of interagency transmission of criminal investigative information, particularly information that identifies subjects, suspects, victims, witnesses, and juveniles. We agree and clarified footnote 18 accordingly.

The status of each recommendation, and the action needed to close the report, are summarized below. Recommendation 1 was directed to the Department. Recommendation 2 was directed to ATF, and recommendations 3 and 4 were directed to the FBI.

  1. Resolved. This recommendation can be closed when we receive documentation from the Department showing that the Repository and BDC databases have been consolidated under ATF management in accordance with the Attorney General's August 11, 2004, directive. Implementation milestones should be established and progress should be reported to the Office of the Inspector General every 90 days.

  2. Resolved. The ATF indicated it has established an MOU with all BATS users and that it will periodically review a statistical sample of the data contained in BATS to check for adherence to the requirements of the MOU. This recommendation can be closed when we receive a copy of the MOU and documentation showing that the ATF has reviewed a statistical sample of the data within BATS.

  3. Unresolved. This recommendation was not addressed by the FBI in its September 23, 2004, response and is therefore unresolved. This recommendation can be resolved and closed when we receive documentation showing that the FBI has developed and implemented policies, procedures, and performance standards to ensure timely and accurate data entry into AIRS.

  4. Resolved. This recommendation can be closed when we receive documentation showing that data from the COBRA server has been transferred to AIRS and that the FBI has taken steps to maximize the use of direct entry of data by participating agencies.