Defense Contracting: Enhanced Information Needed on Contractor Workplace Safety

DOD is the largest contracting agency in the federal government, obligating about $320 billion for contracts in fiscal year 2017. Some DOD contracts—including some in the manufacturing and construction industries—involve work that can be dangerous, and questions have been raised about working conditions for these workers.

The National Defense Authorization Act for Fiscal Year 2018 includes a provision for GAO to review issues related to the safety and health records of DOD contractors. This report examines: (1) the incidence of prior serious safety or health violations among selected companies with DOD manufacturing and construction contracts, and (2) how DOD and selected DOD components address contractor workplace safety and health during the acquisition process. GAO matched federal contracting data for fiscal year 2017 to OSHA inspection data for fiscal years 2013-2017 (most recent available); interviewed officials from OSHA, DOD, selected military departments, and selected DOD components; reviewed documentation from six selected DOD contract files; and reviewed relevant federal laws and regulations, policy, and guidance.

Some selected companies with Department of Defense (DOD) manufacturing or construction contracts in fiscal year 2017 were previously cited for serious safety or health violations, according to GAO's analysis of federal data. Of the 192 companies with DOD contracts GAO selected for review, 106 had been inspected by the Department of Labor's (DOL) Occupational Safety and Health Administration (OSHA) or state occupational safety and health agencies during fiscal years 2013 through 2017. These inspections resulted in 83 companies being cited for at least one violation, including 52 with at least one serious violation (see figure). However, available data do not allow a determination of whether these violations occurred during work on a DOD contract because OSHA inspection data do not include that information.

The incidence of violations among all inspected companies with DOD contracts cannot be determined because OSHA does not require its staff to obtain and enter a corporate identification number in its inspection data, which is needed to match contracting data to inspection data. As a result, OSHA's data do not consistently include these numbers, and users of OSHA's website cannot use these numbers to search for companies' previous violations. According to federal internal control standards, management should share the quality information necessary to achieve the entity's objectives. Unless OSHA explores the feasibility of requiring a corporate identification number in its inspection data, website users will likely have difficulty obtaining accurate information on individual companies' previous violations.

DOD contracting officials have opportunities during the acquisition process to address contractor workplace safety and health. For example, before awarding certain types of contracts, officials may consider workplace safety and health information when they evaluate prospective contractors' performance on past contracts. However, the past performance information that is available for officials to consider varies by DOD component. One component has a practice of requiring construction contractors to be rated on workplace safety at the completion of the contract, but DOD does not require a safety performance rating department-wide. As a result, contracting officials in other components may lack readily accessible information on contractors' past safety performance, and DOD may miss opportunities to consider safety concerns when awarding new contracts, particularly those in high-risk industries with relatively high rates of occupational injuries, such as manufacturing and construction.

GAO is making one recommendation to OSHA and two recommendations to DOD to enhance available information on contractor workplace safety. OSHA neither agreed nor disagreed with GAO's recommendation, but planned to take action to address it. DOD agreed with the recommendations.

The Department of Defense (DOD) is the largest contracting agency in  the federal government, obligating about $320 billion for contracts for  goods and services in fiscal year 2017. Over half of these obligations  were for contracts in the manufacturing and construction industries, which  have relatively high rates of occupational injuries. Reports of worker  injuries and deaths at several companies with DOD contracts have raised  questions about safety for workers employed by DOD contractors and  related oversight. The Department of Labor’s (DOL) Occupational Safety  and Health Administration (OSHA) is the federal agency responsible for  overseeing safety and health-related working conditions for the nation’s  workers, including those employed by DOD contractors.

The National Defense Authorization Act for Fiscal Year 2018 included a  provision for GAO to report on issues related to the safety and health  records of DOD contractors. In this report, we review: (1) the incidence  of prior serious safety or health violations among selected companies with  DOD manufacturing and construction contracts, and (2) how DOD and  selected DOD components address contractor workplace safety and  health during the acquisition process.

To describe the incidence of prior serious safety or health violations  among selected companies with DOD manufacturing and construction  contracts, we matched federal contracting data to OSHA inspection data  for selected contractors. OSHA categorizes a violation as “serious” when  there is a substantial probability that death or serious physical harm could  result, and the employer knew, or could have known with the exercise of  reasonable diligence, of the hazard. First, we used federal contracting  data to select the 100 companies with the largest DOD manufacturing  contracts and the 100 companies with the largest DOD construction  contracts (as measured by federal obligations) in fiscal year 2017. We  focused on the manufacturing and construction industries because they  have relatively high rates of occupational injuries, according to data from  DOL’s Bureau of Labor Statistics (BLS), and over half of DOD contract  obligations in that year were for contracts in these industries, according to  federal contracting data. Next, we identified duplicate or related  companies, and entities that were not private companies with DOD  contracts performed within the United States, and narrowed the list of 200  companies to 192 companies. In fiscal year 2017, DOD obligations for  contracts with these 192 companies accounted for about 79 percent of  DOD’s obligations for contracts in the manufacturing and construction  industries and about 46 percent of DOD’s total contract obligations. We  then matched information about the 192 companies to OSHA’s inspection  data from fiscal years 2013 through 2017.

We assessed the reliability of the federal contracting data and OSHA  inspection data by (1) performing electronic testing of relevant data  elements, (2) reviewing existing information about the data and the  systems that produced them, and (3) collecting information from federal  officials knowledgeable about the data. Based on these reviews, we  found these data to be sufficiently reliable for our purposes. While our  selected companies accounted for nearly half of DOD’s total contract  obligations in fiscal year 2017, our results are not generalizable to all  companies that were awarded DOD manufacturing and construction  contracts in fiscal year 2017. That year, about 29,000 companies had  DOD manufacturing or construction contracts, and we reviewed a non- generalizable sample of 192 companies. In addition, limitations in the  data do not allow a determination of whether the safety and health  violations we identified occurred during work on a DOD contract because  OSHA data do not include that information. Furthermore, our counts of  violations include only those in citations issued by OSHA or state  agencies to our selected contractors as determined by our matching  process, and only those that resulted from closed inspections where the  violations and penalties are considered final. Our counts of violations  exclude any in citations issued only to subcontractors, and might exclude those in citations issued to any of the selected contractors’ subsidiaries or  locations not identified by our matching process.

To review how DOD and selected DOD components address contractor  workplace safety and health in the acquisition process, we reviewed  relevant federal laws and regulations, reviewed relevant DOD policy and  guidance, and interviewed DOD officials. In addition, we selected two  military departments (Army and Navy) and selected two components  within these departments (the U.S. Army Corps of Engineers (USACE)  and the Naval Sea Systems Command (NAVSEA)). We selected the  Army and Navy based on contract obligation amounts, and we selected  USACE and NAVSEA based on the industries in which they award most  of their contracts. We reviewed relevant USACE and NAVSEA policy  and guidance, and interviewed officials from the Army, Navy, USACE,  and NAVSEA. To provide examples of how selected DOD components  address contractor workplace safety and health, we selected a non- generalizable sample of three USACE and three NAVSEA contracts, for  which we reviewed relevant contract file documentation and interviewed  knowledgeable contracting officials. While this review primarily focused  on the award phase of the contracting process, NAVSEA and USACE  officials also provided some information on the pre-award and contract  performance phases of the contracting process, which we include in this  report where relevant. For a detailed description of our objectives, scope,  and methodology, see appendix I.

We conducted this performance audit from February 2018 to February  2019 in accordance with generally accepted government auditing  standards. Those standards require that we plan and perform the audit to obtain sufficient, appropriate evidence to provide a reasonable basis for  our findings and conclusions based on our audit objectives. We believe  that the evidence obtained provides a reasonable basis for our findings  and conclusions based on our audit objectives.

The Federal Acquisition Process and Applicable Provisions

To support its mission, DOD uses contracts to procure many different  types of supplies (such as ships, planes, and munitions) and services  (such as management, maintenance, and technical services). The federal  acquisition process generally includes three phases:  the pre-award phase, which includes acquisition planning and  activities such as conducting market research and defining contract  terms and conditions prior to soliciting proposals;  the award phase, which includes activities such as soliciting offers  from prospective contractors, evaluating prospective contractors’  proposals and qualifications, and awarding the contract; and  the contract performance phase, which includes monitoring contract  performance.

Within these phases, contracting officials complete certain activities as  provided by applicable federal statutes and the Federal Acquisition  Regulation (FAR). These activities differ somewhat based on the unique  circumstances of each contract, including, for example, whether a  contract is awarded competitively through full and open competition or  non-competitively through other than full and open competition, and  whether negotiated procedures are used. (See fig.1.)

Before awarding a contract in excess of the simplified acquisition  threshold (generally $150,000 at the time of our review), the FAR requires  contracting officials to review information in the Federal Awardee  Performance and Integrity Information System (FAPIIS), which can  include descriptions of a prospective contractor’s past safety and health  violations. Furthermore, for competitively awarded acquisitions using  negotiated procedures and expected to exceed the simplified acquisition  threshold, agencies generally must evaluate prospective contractors’ past  performance. Contracting officials enter and view performance  assessments in the Contractor Performance Assessment Reporting  System (CPARS). In evaluating past performance, agencies may review  a contractor’s past performance assessments, which can contain  information about prior safety incidents and may be used to support  award decisions.

While the FAR prescribes policies and requirements that apply to  executive agencies, there can be wide variation concerning the  acquisition practices at individual agencies. For example, USACE often  can take advantage of a robust competitive market and frequently uses  competitively awarded fixed-price contracts. NAVSEA, by contrast,  operates within an industrial base that has far fewer participants that often  are uniquely qualified to produce specific classes of ships. As a  consequence, many of NAVSEA’s contracts are negotiated on a sole- source or limited competition basis.

OSHA’s Oversight of Workplace Safety and Health

Under the Occupational Safety and Health Act of 1970 (OSH Act), OSHA  sets and directly enforces occupational safety and health standards for  the private sector in about half the states. The remaining states have  chosen to set and enforce their own occupational safety and health  standards for these employers under a state plan approved by OSHA.  State standards and their enforcement must be “at least as effective” in  providing safe and healthful employment as the federal standards. Most  private sector employers, including federal contractors, are covered by  the OSH Act and must comply with any applicable state or federal  occupational safety and health standards. In addition to the OSH Act,  several other federal laws require federal contractors, depending on the  type and amount of the contract, to comply with occupational safety and  health standards.

OSHA and the states have approximately 2,100 compliance officers  responsible for enforcing health and safety standards at more than 8  million worksites across the nation, which employ approximately 130  million workers. According to data provided by OSHA officials, in fiscal  year 2017, OSHA and the states conducted about 76,000 inspections. A  little less than half of these inspections were in the construction industry  (about 34,000), and about one-fifth were in the manufacturing industry  (about 14,000).

OSHA and state occupational safety and health agencies conduct both  programmed and unprogrammed inspections. Programmed inspections— which represented about 44 percent of all federal OSHA inspections in  fiscal year 2017—are planned based on workplace injury incidence rates,  previous citation history, or random selection. Programmed inspections  include those conducted under OSHA’s emphasis programs, which focus  on a particular safety or health hazard or a specific industry. OSHA’s nine  current national emphasis programs include one on shipbreaking, which  covers some companies with DOD contracts. In addition, OSHA has  regional and local emphasis programs. Unprogrammed inspections— which represented the other 56 percent of all federal OSHA inspections in  fiscal year 2017—are unplanned and are conducted in response to  reports of imminent danger, fatalities, severe injuries, worker complaints,  referrals from other government agencies, and catastrophic events that  cause worker deaths and hospitalizations.

Before beginning an inspection, OSHA or state compliance officers  generally hold a brief opening conference to inform employer and  employee representatives of the purpose of the inspection and their rights  during the inspection, and provide a copy of the complaint, if applicable.  After completing an inspection, if OSHA or state compliance officers  determine that the employer has violated any safety or health standards,  they may issue a citation, including a deadline for correcting the hazards,  and related financial penalties (see fig. 2). If OSHA issues a citation, it is  required to do so within 6 months of the occurrence of a violation. After  receiving a citation, the employer may request an informal conference  with OSHA officials to present evidence or views that they believe would  support an adjustment to the citation or penalty, but an informal  conference is not required. The employer may also contest the  citation. Employers are required to certify that the hazards have been  corrected by the deadline and provide supporting documentation. If they  do not, OSHA may conduct a follow up inspection, and may issue  additional citations and penalties if the hazards were not corrected.

When an employer is inspected and OSHA finds violations, various  factors might affect the number of violations identified. For example, an  inspection with a narrow focus may identify fewer violations than a full  inspection of the same worksite. OSHA officials said that construction  inspections are often focused on a particular issue, such as protecting  workers from falls or securing a trench, and thus may not be as  comprehensive as a full inspection of a general industry facility. In  addition, the number of violations identified during an inspection could be  affected by factors such as company size, industry, and the presence of  other safety oversight efforts. For example, OSHA officials said that in the  construction industry they routinely cite both a general contractor and a  subcontractor for the same violation, but do so to a lesser extent in other  industries. Officials also noted that on USACE construction sites, both  USACE and contractor representatives conduct safety inspections, which  enhances employer compliance with both OSHA standards and the  USACE Safety and Health Requirements Manual.

Debarment for Violations of Safety and Health Standards

DOL has authority under the Contract Work Hours and Safety Standards  Act to debar federal contractors in the construction industry from receiving  federal contracts if they have committed “repeatedly willful or grossly  negligent” violations of OSHA safety and health standards. However, as  of October 2018, officials said that DOL had not debarred a construction  contractor for this reason in the last 10 years. According to officials,  DOL does not have debarment authority for violations of safety and health  standards in industries other than construction, although it has debarment  authority for other types of labor law violations.

Some Defense Contractors Were Previously Cited for Serious Safety or Health Violations, but Total Incidence is Unknown Because Comprehensive Data Are Not Available

Some Selected Companies with DOD Manufacturing or Construction Contracts in Fiscal Year 2017 Were Previously Cited for Serious Safety or Health Violations

Of the 192 companies we selected with DOD manufacturing or  construction contracts in fiscal year 2017, we found that a little more than  half (106) were inspected by OSHA or state occupational safety and  health agencies from fiscal years 2013 to 2017. Of the companies that  were inspected, 59 had construction contracts, and 47 had manufacturing  contracts in fiscal year 2017. During this 5-year time period, OSHA or  state agencies conducted 609 inspections of these 106 companies. Most  of these inspections (about 81 percent) were conducted by OSHA. The  percentages of programmed and unprogrammed inspections of our  selected companies from fiscal years 2013 to 2017 were similar to these  percentages for all federal OSHA inspections in fiscal year 2017. (See  fig.3.)

OSHA’s enforcement policy is designed to focus OSHA’s inspection  resources on the most hazardous workplaces. Officials told us that  employers, including DOD contractors, may not be inspected if they do  not meet OSHA’s criteria for programmed inspections and do not  experience a safety or health incident that would lead to an  unprogrammed inspection. In addition, officials said employers that  participate in OSHA’s Voluntary Protection Programs (VPP) must have  high-quality safety and health programs, are exempt from regular  programmed inspections, and are only inspected if OSHA is notified of a  safety or health incident. According to OSHA officials, of the 86 selected  companies that were not inspected by OSHA or state agencies from fiscal  years 2013 to 2017, one currently participates in the VPP.

Our analysis found that of the 106 selected companies that were  inspected during this time period, 83 were cited for at least one safety or  health violation of any type, and of those, 52 were cited for serious  violations (when there was a substantial probability that death or serious  physical harm could result, and the employer knew, or could have known  with the exercise of reasonable diligence, of the hazard). Three  companies were cited for at least one repeated violation. (See fig. 4.)  However, we were unable to determine from the available data whether  these safety and health violations occurred during work on a DOD  contract because OSHA inspection data do not include that information.

The 83 selected companies that were cited for workplace safety or health  violations from fiscal years 2013 to 2017 had a total of 405 violations,  including 195 serious violations, 7 repeated violations, and 203 violations  of other types. These companies were assessed financial penalties  totaling about $1.2 million over that time period, including about $742,000  in penalties for serious violations. In fiscal year 2017, the 83 companies  previously cited for violations of any type had DOD contracts totaling  about $113 billion, and the 52 companies previously cited for serious  violations had DOD contracts of $46 billion (as measured by federal  obligations). (See table 1.)

Furthermore, for some of the selected companies cited for serious  violations, the related OSHA inspection data described worker injuries or  deaths. As previously noted, 52 of the selected companies were cited  for a total of 195 serious violations from fiscal years 2013 to 2017. For  some, but not all, of these serious violations, the related inspection data  described accidents in which 7 workers died, 20 were hospitalized for  severe injuries—including fractures, chemical burns, other burns, and  amputations—and 4 had severe injuries that did not require  hospitalization. According to the inspection data, the accidents in which  7 workers died included the following: a hydrogen blast in a melting chamber resulted in one worker being  pinned under a 20,000 pound lid, another receiving second degree  burns, and a third being killed; a barge capsized after a crane tilted over, and one worker drowned; a worker fell 98 feet from an elevator and was killed; a worker sustained a fatal electric shock when replacing jumper wires  on a high voltage transmission corner tower, and another worker was  injured; an autoclave exploded, striking and killing a worker with extreme a vessel became unmoored due to high winds and struck a pier which  then collapsed, pulling two workers underwater, one of whom died.

The Incidence of Violations among All Inspected Companies with DOD Contracts Is Unknown Because OSHA’s Data Do Not Consistently Include Corporate Identification Numbers

While we could identify some selected companies with DOD contracts in  fiscal year 2017 that were previously cited for safety or health violations,  the incidence of these violations among all inspected companies with  DOD contracts is unknown because data limitations prevent  comprehensive matching of federal contracting data with OSHA  inspection data. Specifically, the corporate identification numbers used in  the federal contracting databases—the Employer Identification  Number/Taxpayer Identification Number (EIN/TIN) and the Data Universal  Numbering System (DUNS) number—are not well-populated in OSHA’s  database because OSHA has not designated them as required fields.  OSHA officials are required to enter certain types of data in OSHA’s  inspection database—such as the employer’s name and address, the  type of inspection, and any violations that were identified during the  inspection—and have the option to enter the employer’s EIN/TIN and  DUNS number. However, at the time of our review, for manufacturing and  construction inspections initiated from fiscal years 2013 to 2017, the EIN/TIN of the inspected company was entered in OSHA’s inspection  data for about one-third of all inspections, and the DUNS number was  entered for about 8 percent of all inspections (see fig. 5). OSHA has  acknowledged that it is difficult to match records across different  databases without corporate identification numbers.

In addition, OSHA’s website with information about safety and health  violations cannot currently be searched by a company’s EIN/TIN or DUNS  number. OSHA makes information about violations publicly available on its website, which can be searched by company name and industry code,  among other fields. However, when searching OSHA’s website by  company name, interested parties may experience challenges obtaining  relevant information because company names differ across databases.  When we searched the OSHA website by company name as part of  selecting USACE and NAVSEA contracts for review, we were unable to  determine whether 18 of the 66 company names we searched had been  inspected. For example, when we searched the OSHA website using the  first word in one company’s name, the search results included 34  inspections, but none of the company names in the search results exactly  matched the company name in the federal contracting data.

OSHA officials said the EIN/TIN and DUNS numbers are not required  fields because employers or their on-site representatives do not always  have these numbers. Officials told us that smaller companies, such as  small construction companies, are less likely to have these numbers than  larger companies. When companies do have corporate identification  numbers, officials said that the employer’s on-site representative who  interacts with the OSHA compliance officer—such as a foreman—might  not know these numbers, and OSHA officials may not have the  opportunity to meet with other employer representatives who would be  more likely to know these numbers. However, if an employer requests an  informal conference with OSHA officials after being cited for a violation,  the conference provides an opportunity for OSHA officials to obtain the  employer’s corporate identification number from knowledgeable  representatives. In addition, OSHA officials said requiring a corporate  identification number in OSHA’s inspection database could prevent  closing an inspection record and issuing any related citations if they were  unable to obtain this number within the required six-month timeframe.  Officials added that delays in issuing citations could also lead to delays in  addressing workplace hazards, because employers are not required to  begin addressing these hazards until they receive a citation. However,  OSHA officials noted that if an employer’s EIN/TIN or DUNS number is  not available during an inspection, the number can be added to the  inspection database at a later time.

Collecting corporate identification numbers as part of inspections could  benefit both OSHA and users of OSHA’s website. OSHA officials said that  the EIN is useful for collecting financial penalties from companies that  have been cited for violations. In addition, OSHA officials told us that  requiring the EIN/TIN or DUNS number in OSHA’s inspection database  would make it easier to search for companies in OSHA’s online inspection  data. According to federal internal control standards, management should  externally communicate the necessary quality information to achieve the  entity’s objectives. Quality information is appropriate, current, complete,  accurate, accessible, and provided on a timely basis. Without exploring  the feasibility of requiring a corporate identification number in OSHA’s  inspection database and enabling OSHA’s website to be searched by that  number, contracting officials and other interested parties are likely to  experience challenges obtaining accurate information about companies’  safety and health violations.

DOD Officials Have Several Opportunities to Address Workplace Safety and Health During the Acquisition Process, but May Not Have Complete Information

Officials at DOD have multiple opportunities to address contractor safety  throughout the acquisition process. For example, during the award phase,  officials can consider safety information when they evaluate contractors’  past performance for contracts awarded competitively using negotiated  procedures. However, not all contracting officials are aware that relevant  contractor safety information is available on the OSHA website. During  the contract performance phase, USACE and NAVSEA both take  additional steps related to contractor safety and health, including accident  prevention and accident reporting. Only USACE, however, has a practice  of requiring contracting officials to assess contractor safety performance  on construction contracts at the completion of the contract. As a  consequence, safety performance information for other contracts across  DOD may not be readily accessible to officials when awarding new  contracts.

While Not Required, DOD Can Consider Workplace Safety and Health in Various Ways Before Awarding Contracts

The FAR does not specifically require contracting officials to consider  information about prospective contractors’ records of safety performance  before awarding a contract. Furthermore, DOD, Army, Navy, USACE, and  NAVSEA policy and guidance do not specifically direct contracting  officials to consider information about prospective contractors’ safety  records before awarding contracts, according to officials. However,  contracting officials have several opportunities to consider contractor  safety and health records and other safety information during the pre- award and award phases of the contracting process.

Developing requirements and drafting the solicitation. As part of  acquisition planning, contracting and program officials develop  requirements. In addition, when drafting a solicitation, the FAR or agency  guidance may prescribe the use of certain clauses. For example, the FAR  requires that fixed-price construction contracts above the simplified  acquisition threshold include a provision related to workplace safety.  Specifically, these contracts must include an Accident Prevention clause  that requires the contractor to provide appropriate safety barricades,  signs, and signals, and comply with OSHA safety and health standards,  among other requirements. In addition, for DOD construction fixed-price  contracts above the simplified acquisition threshold, this Accident  Prevention clause requires contractors to comply with the USACE Safety  and Health Requirements Manual. USACE contracting officials also told  us that if contracts include work associated with asbestos abatement,  lead abatement, or hazardous waste remediation, clauses specific to  these areas are also included in the solicitation and resulting contract.  NAVSEA also uses clauses as applicable to the specific work performed,  for shipbuilding procurements or ship repair, in its contracts, and  NAVSEA stated that many of these clauses are related to safety and  environmental issues. Further, program officials can include specific  requirements for unique or high-risk activities. For example, one of our  selected NAVSEA contracts specified that the contractor must ensure that  all required safety and emergency devices, such as emergency escape  breathing devices, were onboard the ship before the contractor conducted  sea trials.

Soliciting and evaluating offers from prospective contractors. For  contracts awarded competitively using negotiated procedures, contracting  officials are required to identify the factors on which they will evaluate  prospective contractors’ proposals and their relative weights. Contracting  officials can designate safety in the solicitation as among the criteria that  they will use to evaluate proposals and require prospective contractors to  submit related information. For example, solicitations for two of our  selected contracts included aspects of safety in the evaluation of certain  factors.

Safety also may be considered during the evaluation of contractor past  performance. For acquisitions following negotiated procedures that are  expected to exceed the simplified acquisition threshold, the FAR  generally requires an evaluation of prospective contractors’ past  performance, which can include compliance with safety requirements on  past contracts. The evaluation must include past performance as an  evaluation factor unless the contracting officials document the reason  past performance is not an appropriate evaluation factor for the  acquisition. In evaluating past performance, the contractor’s performance  assessments in CPARS may be reviewed and used by contracting  officials to support future award decisions. For example, for one  NAVSEA contract, the assessments identified instances when the  contractor’s safety program failed to comply with NAVSEA’s safety  standards. In noncompetitive acquisitions following negotiated  procedures, there is no requirement that there be evaluation criteria that  include past performance. In these situations, opportunities for  considering safety issues may be limited to the responsibility  determination.

Determining that contractors meet responsibility standards. Prior to  contract award, contracting officials must determine that prospective  contractors are “responsible,” which is also known as the responsibility  determination. The responsibility determination has several required  elements, some of which may include consideration of workplace safety  and health. For example, before awarding a contract, contracting  officials must: determine that prospective contractors have the necessary  organization, experience, accounting and operational controls, and  technical skills, or the ability to obtain them, which may include  assessing whether contractors have applicable safety programs;  and determine that prospective contractors have a satisfactory  performance record which for contracts that will be in excess of the  simplified acquisition threshold includes reviewing and considering  prospective contractors’ performance and integrity information in  FAPIIS, which may include information about proceedings related to  safety and health violations.

For one of our selected contracts, the FAPIIS search result in the contract  file described OSHA safety and health violations. While they were not  required to do so, none of the responsibility determinations for our six  selected contracts contained information about workplace safety. If  contracting officials considered safety when making this determination,  we did not locate it in the contract files.

Information on Safety in Performance Assessments Varies and Can Be Incomplete

The information available to contracting officials in the federal contracting  databases about contractors’ past performance varies by DOD  component. Specifically, USACE has a practice of requiring officials to  assess and rate contractors’ performance on construction contracts with  respect to safety, among other required factors, in CPARS at the  completion of the contract. USACE contracting officials enter a safety  performance rating—exceptional, very good, satisfactory, marginal, or  unsatisfactory—and provide a supporting written narrative in a specific  tab in CPARS. As a result, information on safety performance is  summarized in a single location within CPARS, and thus, readily  accessible to federal contracting officials, including those at DOD, when a  previous USACE construction contractor is considered for future contract  awards. For all other DOD contracts, according to officials we  interviewed, information on contractors’ safety performance may be  included in various places throughout CPARS, but is not required to be  summarized as a separate rating in a single location.

The contract file documentation we reviewed illustrated these differences.  For two of our selected USACE contracts, we found that this safety  performance rating was available to officials for their consideration when  awarding the contract. Based on our review of the contract file for one of  these contracts, source selection officials identified less than satisfactory  comments related to the safety performance rating in CPARS. As a result,  they considered the rating, as well as the actions explained by the  contractor to mitigate the safety issues. These officials determined that  the corrective actions were sufficient, according to the documentation we  reviewed. In contrast, for one of our selected NAVSEA contracts, we  found that the past performance assessments in CPARS contained no  information about workplace safety or health—either satisfactory or  unsatisfactory. The past performance for the remaining NAVSEA contract  file for which we obtained a CPARS report contained information on  workplace safety and health—for example, the assessments noted  corrective action requests were submitted for safety incidents.

According to federal internal control standards, management should use  quality information—information that is complete and accessible—to  achieve its objectives. Without a safety performance rating for  contractors in industries with relatively high rates of occupational injuries,  such as manufacturing or ship building and repairing, contracting officials  may lack complete, readily accessible information on prospective  contractors’ workplace safety performance. As a result, DOD may miss  opportunities to address safety and health concerns when awarding  contracts in these high-risk industries—for example, by considering  whether and how prospective contractors resolved or mitigated violations  or safety issues on prior contracts.

In addition, DOD contracting officials may not be aware that the OSHA  website is a resource for additional information about contractors’  workplace safety and health records. Since CPARS only includes past  performance assessments for federal government contracts, contracting  officials may not know about OSHA violations committed by companies  during work that took place outside of these contracts, or when the  company was not a federal contractor. DOD officials told us that they  expect contracting officials to use their discretion in evaluating safety  performance; however, DOD has not advised its contracting officials that  the OSHA website is a resource for additional information on workplace  safety records. For one of our selected contracts, the contracting official  told us he was not aware of a past OSHA violation when determining  contractor responsibility. According to the contracting official, OSHA  issued the citation for non-Navy work performed at the contractor’s  commercial shipyard. Several contracting officials told us that they would  likely only consider violations they deemed relevant, for example, those  that occurred at the facility where the contract will be performed.  However, without knowing that a past violation occurred, the official we  interviewed for our selected contract may not have had the opportunity to  consider all of the available information when evaluating the contractor or  addressing potential safety issues.

Moreover, contracting officials for the six USACE and NAVSEA contracts  we reviewed said they have not sought information about contractor  safety and health violations from the OSHA website, and several were  unaware that the website contained information on violations. Without  being made aware that the OSHA website is a resource for additional  information, contracting officials may not have the opportunity to utilize all  of the available information about prospective contractors’ safety history.  As a result, DOD contracting officials may miss opportunities to consider  safety and health concerns when they are awarding new contracts.

Selected Components Take a Variety of Steps to Address Contractor Workplace Safety During Performance of the Contract

Officials from our two selected components—USACE and NAVSEA—also  identified various actions they may take during the contract performance  phase related to the workplace safety of their contractors. For example,  according to officials, during the contract performance phase, USACE  and NAVSEA oversee contractors’ compliance with contract requirements  related to workplace safety and health. The steps they take may include  ensuring that contractors submit accident prevention plans, when  required, and conducting safety inspections, among other actions.

Monitoring for OSHA violations. As mentioned above, the FAR requires  a clause regarding compliance with safety and health standards to be  included in certain federal construction contracts. USACE officials told  us that this is monitored as a reportable item while work is being  conducted, and that if violations occur during the performance of the  contract, the contracting official is to enter information about the violations  into CPARS. An Army official also told us that the Army recently  implemented a system to track OSHA violations, but that it did not yet  contain any data.

Accident prevention. The FAR requires compliance with the USACE  Safety and Health Requirements Manual for certain DOD construction  contracts. According to the manual and USACE officials, USACE does  not allow construction to begin until officials have reviewed and accepted  the contractor’s accident prevention plan, including changes if necessary.  For example, the contract documentation we reviewed for a dredging  contract included a memorandum outlining changes that were to be  addressed in the accident prevention plan (for example, outlining  credentials for the safety officer on the site). According to the manual,  USACE requires contractors’ submitted accident prevention plans to be  job-specific and include work to be performed by subcontractors.

NAVSEA may require contractors to submit an occupational health and  safety plan for ship repair work. For example, one of the files we reviewed  for a maintenance, modernization, and repair contract for a certain class  of ships included a safety plan—a required deliverable under the  contract—covering topics such as fall protection, evacuation procedures,  and accident notification.

Inspections. The USACE manual requires daily safety inspections of  contractors’ worksites by both contractor and USACE personnel, and  officials told us that USACE procedures require these inspections to be  entered in USACE’s Resident Management System. The manual also  requires the accident prevention plan or the USACE project safety and  occupational health plan to provide for “frequent” safety inspections of the  work sites, material, and equipment to ensure compliance with the plan  and the USACE manual. For one of the USACE contracts we selected for  review, CPARS documentation provided by USACE officials indicated  that USACE staff noted repeated issues with safety requirements,  including exposed live electrical wiring, lack of adequate lighting, and  improper use of extension cords. This CPARS example indicates that the  contractor worked to increase safety compliance. Finally, USACE’s  manual states that when an employee is deemed to be in imminent  danger, contractor or USACE officials must immediately stop the unsafe  work being performed.

For NAVSEA, officials told us that safety requirements and oversight  responsibilities will vary depending on the type of work involved. For new  construction, the Navy Supervisor of Shipbuilding, Conversion, and  Repair (SUPSHIP) oversees safety. For repair and maintenance, the  Regional Maintenance Centers are charged with safety oversight, among  other administrative responsibilities. At both organizations, if problems are  found, personnel issue corrective action requests. For example, a  regional maintenance center staff member issued a corrective action  request because the contractor failed to monitor the use of personal  protective equipment and a contractor employee fell through a deck  opening. As previously noted, the CPARS assessments for one of our  selected contracts specifically noted that safety corrective action requests  had been issued to that contractor. NAVSEA officials told us that quality  assurance staff also have regular meetings with the contractors and  monitor workplace safety.

Accident reporting. USACE policy is to investigate and report USACE  accidents in order to prevent recurrences and to comply with OSHA,  DOD, Army, and other requirements. USACE regulation requires  contracting officials to inform contractors of their responsibilities for  accident reporting and investigation, and ensure all accidents that occur  within their area of responsibility are investigated and reported. USACE  also collects information about accidents at contractors’ worksites, and  disseminates summaries of incidents on a regular basis. For example,  one summary described a fall by a contractor employee resulting in  stitches and a broken nose. The summary reminds USACE personnel of  the importance of protective equipment to prevent this type of incident.  USACE officials also told us that they have on-site engineers who would  typically address any safety concerns directly with the contractor and  inform the contracting official responsible for entering information into  CPARS.

Navy policy requires significant problems, including severe personnel  injuries, to be reported to the NAVSEA Commander through the use of  trouble reports. In addition, the SUPSHIP supervisor implements hazard  identification and reporting processes and ensures the collection,  evaluation and reporting of data for the determination of contractor award  fees and past performance data bases. SUPSHIP also assesses the  overall effectiveness of contractor safety and health management  systems and provides safety program assessments for quarterly reviews.  Finally, the SUPSHIP Operations Manual provides that SUPSHIP  personnel who are aware of any major or willful contractor violation of  federal, state, or local laws and regulations (for example, recurring/major  unsafe work practices) will report these violations.

Personnel training. According to a USACE official, USACE requires the  designated quality control manager for each worksite to take the USACE  Construction Quality Management course before being approved to work  on a project. The course aims to ensure that construction is performed  according to plans and specifications, on time, within budget, and in a  safe work environment. In addition, contractor safety managers are  required by the USACE manual to be on all project sites for USACE  construction contracts and must complete certain OSHA training or  equivalent training. This program provides training on the recognition,  avoidance, abatement, and prevention of workplace hazards.

According to officials, NAVSEA recommends that its personnel working in  acquisition of defense systems or maintenance of ships and aircraft  undergo acquisition safety training. A NAVSEA contracting official told us  that the first draft of this training has been developed and will be required  training for NAVSEA contracting personnel. Officials said that the aim of  this training is ensure that safety is considered when developing contract  requirements.

DOD obligates hundreds of billions of dollars each year on contracts,  including those for work in high-risk industries such as construction and  ship building and repairing, and some companies have received DOD  contracts after being cited for serious workplace safety or health  violations. Even if these violations did not occur during work on a DOD  contract, they could be relevant to decisions about new DOD contracts,  for example, when a prospective contractor has not previously received  federal contracts or when past performance information does not address  workplace safety.

However, the incidence of serious safety and health violations among all  inspected DOD contractors remains unknown because OSHA does not  require a corporate identification number in its inspection data.  Furthermore, OSHA’s website currently cannot be searched by a  corporate identification number. Without these enhancements to OSHA’s  inspection data and website, DOD contracting officials and other  interested parties are likely to experience challenges obtaining accurate  information about contractors’ workplace safety and health records.

In addition, DOD contracting officials may be unaware of OSHA’s website  because DOD has not advised them that this resource exists. Despite  some data limitations, OSHA’s website currently can be used to obtain  information about contractors’ workplace safety and health records in  some cases. While DOD contracting officials are not required to consider  information about contractors’ workplace safety and health before  awarding contracts, they have multiple opportunities to do so. Unless  DOD provides information about OSHA’s website to contracting officials,  they may remain unaware that this resource exists, and may miss  opportunities to consider safety and health concerns when awarding new  contracts.

Furthermore, some DOD contracting officials may lack readily accessible  information on contractors’ past workplace safety performance because  DOD does not require a safety performance rating for contracts  department-wide. One of the DOD components we selected has a  practice of requiring construction contractors’ performance to be rated  with respect to workplace safety at the completion of each contract.  However, DOD does not require a safety performance rating for other  components’ construction contracts or contracts in other industries with  similarly high rates of occupational injuries, such as manufacturing.  Without exploring the feasibility of requiring a department-wide safety  performance rating for all contracts in high-risk industries, DOD may miss  opportunities to reduce risks by considering safety concerns when  awarding new contracts in these industries.

We are making three recommendations, including one to OSHA and two  to DOD. Specifically:  The Assistant Secretary of Labor for Occupational Safety and Health  should explore the feasibility of requiring a corporate identification number  in its inspection database and enabling its website to be searched by that  number. This should include exploring the following issues: which corporate identification number would be most appropriate to options for obtaining this number from employers; and options for entering this number in its database that would prevent or  minimize delays in closing inspection records. (Recommendation 1)

The Secretary of Defense should provide information to contracting  officials to advise them that the OSHA website is a resource for  information about contractors’ workplace safety and health records.  (Recommendation 2)

The Secretary of Defense should explore the feasibility of requiring a  safety performance rating for contracts in industries that have relatively  high rates of occupational injuries, such as manufacturing, construction,  and ship building and repairing. (Recommendation 3)

We provided a draft of this report to DOL and DOD for review and  comment. DOL’s Occupational Safety and Health Administration (OSHA)  and DOD provided written comments, which are reprinted in appendixes  II and III, respectively.

With respect to our first recommendation that OSHA explore the feasibility  of requiring a corporate identification number in its database and enabling  its website to be searched by that number, OSHA did not state whether it  agreed with our recommendation. OSHA acknowledged the potential  utility of obtaining a unique identifier from each employer and said it will  continue to promote the collection of Employer Identification Numbers  (EIN) or Tax Identification Numbers (TIN) whenever possible by issuing a  revised memorandum to field staff to reinforce the importance of  collecting this information. OSHA stated that it does not view EINs as  confidential or protected from disclosure. However, OSHA expressed  concerns about protecting TINs and Social Security Numbers from  disclosure, and noted that it would not be able to make a data field  available for public search if it contained either of these numbers. OSHA  also raised concerns about the financial cost associated with redesigning  the agency’s data system. We encourage OSHA to explore options for  addressing these concerns as it further considers how to implement our  recommendation.

With respect to our second and third recommendations that DOD provide  information to contracting officials about the OSHA website and explore  the feasibility of requiring a safety performance rating for contracts in  high-risk industries, DOD agreed with both recommendations and  identified implementation timelines.

We are sending copies of this report to the appropriate congressional  committees, the Secretary of the Department of Labor, the Secretary of  the Department of Defense, and other interested parties. In addition, the  report is available at no charge on the GAO website at  http://www.gao.gov.

If you or your staff have any questions about this report, please contact  William T. Woods at (202) 512-4841 or woodsw@gao.gov, or Chelsa  Gurkin at (202) 512-7215 or gurkinc@gao.gov. Contact points for our  Offices of Congressional Relations and Public Affairs may be found on  the last page of this report. GAO staff who made key contributions to this  report are listed in appendix IV.

This report examines (1) the incidence of prior serious safety or health  violations among selected companies with Department of Defense (DOD)  manufacturing and construction contracts, and (2) how DOD and selected  DOD components address contractor workplace safety and health during  the acquisition process.

To describe the incidence of prior serious safety or health violations  among selected companies with DOD manufacturing and construction  contracts, we matched federal contracting data to the Department of  Labor’s (DOL) Occupational Safety and Health Administration (OSHA)  inspection data for selected contractors, interviewed OSHA officials, and  reviewed relevant OSHA policy. Our data matching process is described  below. To describe how DOD and selected DOD components address  contractor workplace safety and health during the acquisition process, we  selected two military departments (Army and Navy) and two components  within these departments (the U.S. Army Corps of Engineers (USACE)  and the Naval Sea Systems Command (NAVSEA)). We interviewed  officials from DOD and these departments and components, and  reviewed relevant DOD and component-level policy and guidance. To  provide illustrative examples, we selected a non-generalizable sample of  three USACE and three NAVSEA contracts, reviewed relevant contract  file documentation, and interviewed knowledgeable contracting officials.   Our criteria for selecting contracts and our review of contract file  documentation are described below. While this review primarily focused  on the award phase of the contracting process, NAVSEA and USACE  officials also provided some information on the pre-award and contract  performance phases of the contracting process, which we include in this  report where relevant. For example, we interviewed USACE and  NAVSEA safety officials about safety oversight practices during the  contract performance phase. We also obtained examples of safety- related requirements for each of our selected contracts by interviewing contracting officials and reviewing contract documentation. To address  both objectives, we reviewed relevant federal laws and regulations.

To describe the incidence of prior serious safety or health violations  among selected companies with Department of Defense (DOD)  manufacturing and construction contracts, we matched federal  contracting data to OSHA inspection data. OSHA categorizes a violation  as “serious” when there is a substantial probability that death or serious  physical harm could result, and the employer knew, or could have known  with the exercise of reasonable diligence, of the hazard. Specifically, we  matched contracting data from the Federal Procurement Data System- Next Generation (FPDS-NG) and the System for Award Management  (SAM) to inspection data from the Occupational Safety and Health  Information System (OIS) and Integrated Management Information  System (IMIS). We assessed the reliability of the federal contracting data  and OSHA inspection data by (1) performing electronic testing of relevant  data elements, (2) reviewing existing information about the data and the  systems that produced them, and (3) collecting information from federal  officials knowledgeable about the data. Based on these reviews, we  found the employer identification information in the federal contracting  data, obligation amounts in the federal contracting data, and the OSHA  inspection data to be sufficiently reliable for our purposes.

First, we used FPDS-NG data to select the 100 companies with the  largest DOD manufacturing contracts and the 100 companies with the largest DOD construction contracts (as measured by federal obligations)  in fiscal year 2017. We focused on the manufacturing and construction  industries because they have relatively high rates of occupational injuries,  according to data from DOL’s Bureau of Labor Statistics (BLS), and over  half of DOD contract obligations in that year were for contracts in these  industries, according to FPDS-NG data. Next, we identified duplicate or  related companies, and entities that were not private companies with  DOD contracts performed within the United States, and narrowed this list  of 200 companies to 192 companies. In fiscal year 2017, DOD  obligations for contracts with these 192 companies accounted for about  79 percent of DOD’s obligations for contracts in the manufacturing and  construction industries and about 46 percent of DOD’s total contract  obligations.

Then, to determine whether the 192 companies had been inspected by  OSHA or state occupational safety and health agencies from fiscal years  2013 to 2017, we used automated matching procedures that compared  the Employer Identification Numbers (EINs) and company names entered  in the federal contracting databases to those entered in OSHA’s  inspection databases. Specifically, we used FPDS-NG to identify the Data  Universal Numbering System (DUNS) numbers for our selected  companies, and then used SAM to identify the EINs that corresponded to  each of those DUNS numbers. Next, we matched those EINs to the EINs  in the OSHA inspection data. We considered a company to be a match if  the EINs were identical and either (1) the company names were the same  or similar, or (2) the company names were different, but we identified a  relationship between the two company names, such as a parent  company/subsidiary relationship, through an internet search. Using this  process, we initially identified 90 selected companies that were inspected  by OSHA from fiscal years 2013 to 2017.

After completing this matching process, we sent a list of the remaining  companies that we were unable to match to OSHA for review.  Specifically, we asked OSHA officials to identify whether those  companies were inspected from fiscal years 2013 to 2017, and provide  inspection numbers for those companies that were inspected. OSHA  officials reviewed this list and reported that OSHA had inspected some of  the unmatched companies, and provided related inspection numbers. We  then added those inspections to our analysis, which brought the total  number of selected companies inspected by OSHA during this time  period to 106 of 192.

Our results are not generalizable to all companies that were awarded  DOD manufacturing and construction contracts in fiscal year 2017. That  year, about 29,000 companies had DOD manufacturing or construction  contracts, and we reviewed a non-generalizable sample of 192  companies. In addition, limitations in the data do not allow a  determination of whether the safety and health violations we identified  occurred during work on a DOD contract because OSHA data do not  include that information.

Our counts of violations include only those in citations issued by OSHA or  state agencies to our selected contractors as determined by our matching  process, and only those that resulted from closed inspections where the  violations and penalties are considered final. In addition, our counts of  violations exclude any in citations issued only to subcontractors.  According to OSHA officials, in certain circumstances, OSHA may cite  both a prime contractor and a subcontractor for a violation, but in these  cases the data would be recorded under two separate inspection  numbers, which may or may not be linked in OSHA’s database. As a  result, we did not attempt to identify inspections and violations for  subcontractors. Furthermore, our counts of violations might exclude those  in citations issued to any of the selected contractors’ subsidiaries or  locations not identified by our matching process. We counted inspections  and violations at the parent company level. Many of the companies we  selected had multiple locations, and some may have had subsidiaries.  OSHA inspections take place at the local worksite level. As a result, the  number of violations we report reflects the total number of violations we  identified across the selected companies’ various locations or subsidiaries  that were inspected from fiscal years 2013 to 2017. To the extent that our  matching process did not capture every company location or subsidiary,  our findings may underestimate the actual number of inspections and  violations among our selected companies.

Contract Selection and Review of Contract File Documentation

To provide examples of how selected DOD components address  contractor workplace safety and health during the acquisition process, we  selected a non-generalizable sample of three USACE and three NAVSEA  contracts. To select these contracts, we first identified the 50 companies  with the largest DOD construction contracts and the 50 companies with  the largest DOD manufacturing contracts (as measured by federal  obligations) in fiscal year 2017. Because our review focused on USACE  and NAVSEA, we narrowed this list to USACE construction contractors  (45) and NAVSEA shipbuilding or ship repair contractors (18). Next, we  searched OSHA’s online inspection data to determine whether these  contractors were cited for serious workplace safety or health violations within the last five years (fiscal years 2013 to 2017). Then, we selected  the three USACE contractors and the three NAVSEA contractors that had  the highest number of serious violations for closed OSHA inspections.  We counted serious violations at the parent company level, which may  include violations at different company locations. For example, OSHA  violations we identified for one selected contractor occurred during both  tank manufacturing and ship repair at different locations within the United  States.

After selecting these six companies, we identified the new USACE and  NAVSEA contracts that were awarded to each selected company in fiscal  years 2017 and 2016. We selected contracts that were awarded in fiscal  year 2017 or 2016 because we expected that documentation for those  contracts would be more readily available than for contracts awarded in  previous years.

Starting with the contracts that were awarded in fiscal year 2017, we  selected one contract for each of these six contractors that had the  highest total contract value (including base and all options) and provided  diversity with respect to the contracting office that awarded the contract  and the location where the work was performed. We excluded contracts  that were for design or planning, rather than actual construction,  shipbuilding, or ship repair. We also considered the proximity of the  violation dates to the contract award date, and excluded contracts where  all of the violations occurred after the contract was awarded, or  immediately before the contract was awarded. In three cases, to satisfy  these inclusion and exclusion criteria, it was necessary to select a  contract that was awarded in 2016 and/or a contract that had the second  highest total value. Each of our six selected contracts had a total contract  value that was above the simplified acquisition threshold, which for the  timeframe of our sample was generally above $150,000. (See table 2.) Of  these six contractors, two had prior OSHA violations that occurred at the  same location where the work on the selected contract was performed.  However, we were unable to determine from the available data whether these violations occurred during work on a prior DOD contract, because  OSHA data do not include that information.

For each of the six selected contracts, we reviewed available relevant  documentation in the contract file to determine how, if at all, officials  considered information about contractors’ workplace safety and health in  awarding the contract. These documents—depending on the type of  source selection—included the contract solicitation, source selection plan,  evaluation of contractor proposals, and the responsibility determination. In  addition, we interviewed the contracting officials who awarded each of the  six contracts to discuss how and why they considered available  information about contractors’ workplace safety and health before  awarding the contract, including whether this information was considered  as part of the responsibility determination. We also determined whether  prior OSHA violations were recorded in the Federal Awardee  Performance and Integrity Information System (FAPIIS), to the extent  these records were saved in the contract file. In addition, we obtained  and reviewed Contractor Performance Assessment Reporting System  (CPARS) reports for any information about occupational safety and health  performance on past contracts, such as comments on safety practices or  accidents, or the presence of safety ratings, as available in the files. The  results of this review of contract file documentation cannot be  generalized.

We conducted this performance audit from February 2018 to February  2019 in accordance with generally accepted government auditing  standards. Those standards require that we plan and perform the audit to  obtain sufficient, appropriate evidence to provide a reasonable basis for  our findings and conclusions based on our audit objectives. We believe  that the evidence obtained provides a reasonable basis for our findings  and conclusions based on our audit objectives.

Appendix II: Comments from the Department of Labor

Appendix IV: GAO Contacts and Staff Acknowledgments

In addition to the contacts named above, Betty Ward-Zukerman  (Assistant Director), Caitlin Croake (Analyst-In-Charge), Amy Sweet,  Sonja Bensen, and Cathy Roark made key contributions to this report.  Also contributing to this report were Marie Ahearn, Blake Ainsworth,  Hiwotte Amare, Vincent Balloon, James Bennett, Linda Collins, Sarah  Cornetto, Holly Dye, Andrea Evans, Laurier Fish, Suellen Foth, Kristen  Jones, Sheila McCoy, Jean McSween, Diana Moldafsky, Stacy Ouellette,  Anh Nguyen, Jason Rodriguez, Almeta Spencer, Kelly Turner, Kristin Van  Wychen, Alyssa Weir, and Eve Weisberg.

Contracts awarded by the Department of Defense can include work that is physically demanding and dangerous, like construction and manufacturing.

We found some defense contractors had been cited for safety or health violations.

The Occupational Safety and Health Administration doesn't collect data that could be used to match federal contracts with violations, so it's not always possible to know whether the violations occurred on defense contracts. Also, DOD doesn't always require contractors to be rated on safety.

We recommended DOD and OSHA improve the use and availability of information about workplace safety for defense contractors.