oversight

SIGAR-20-30-IP

Published by the Office of the Special Inspector General for Afghanistan Reconstruction on 2020-03-23.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

SIGAR                                                      Special	Inspector	General	for	
                                                            Afghanistan	Reconstruction	




                                                                          SIGAR 20-30 Inspection Report



     Afghan Ministry of Commerce and Industries
     Replacement Building in Kunduz Province: Some
     Construction Deficiencies Were Not Addressed
     and the $3.5 Million Building May Not be in Use




                                                                                     MARCH
                                                                                     2020
SIGAR 20-30-IP/Ministry of Commerce and Industries Replacement Building
March 23, 2020


The Honorable Dr. Mark T. Esper
Secretary of Defense

General Kenneth F. McKenzie Jr.
Commander, U.S. Central Command

General Austin Scott Miller
Commander, U.S. Forces–Afghanistan and
  Commander, Resolute Support

Lieutenant General Todd T. Semonite
Commanding General and Chief of Engineers,
   U.S. Army Corps of Engineers

Brigadier General Brian N. Wolford
Deputy Commander, U.S. National Support
   Element–Afghanistan


This report discusses the results of SIGAR’s inspection of the Ministry of Commerce and Industries (MOCI)
replacement building in Kunduz Province. In September 2016, the U.S. Army Corps of Engineers (USACE)
awarded a $3.2 million firm-fixed-price contract to Technologists Inc. (TI), a U.S. company, to design and
construct a building for the MOCI, whose previous building was damaged by a U.S. airstrike in October 2015.
The contract also required TI to clear mines and unexploded ordinance, demolish and remove all debris, and
conduct a geotechnical investigation and topographical site survey. Following three contract modifications, the
contract value increased to $3.5 million.
During our February and August 2019 site visits, we found that TI generally constructed the building according
to contract requirements. However, we identified five construction deficiencies involving (1) building expansion
joints that were not filled with the required material, (2) p-traps that were improperly installed under the sinks,
(3) hot water pipes that were not insulated, (4) counterfeit fire extinguishers, and (5) electrical cable
identification tags that were missing. After SIGAR alerted USACE to these deficiencies in May 2019, USACE
stated that it would direct TI to correct four of the five deficiencies. However, during an August 2019 follow-up
inspection, we found that TI had only addressed one of the five deficiencies.
We also found that neither USACE nor U.S. Forces–Afghanistan (USFOR-A) followed transfer, acceptance, and
warranty procedures. USACE determined that the project was ready for transfer to USFOR-A on June 22, 2018,
which began the 1-year construction warranty period. However, USFOR-A did not transfer the replacement
building to the MOCI until March 20, 2019. This resulted in MOCI only receiving about 3 months of warranty
coverage on the building and its systems. Further, during the more than 8-month delay in transferring the
building, the U.S. government spent over $250,000 on security and maintenance services at the building
During our August 2019 site visit, we found that the MOCI replacement building had not been used since its
completion in June 2018. Although we inquired in October 2019, USFOR-A did not responded about whether
the building is currently in use.
We are making two recommendations in this report. We recommend that the Commander of USFOR-A (1) notify
the MOCI of the replacement building’s construction deficiencies so MOCI can take whatever action it deems
appropriate to (a) fill the expansion joints with proper sealant, (b) install p-traps in the correct locations, (c)
insulate the hot water pipes, and (d) replace the counterfeit fire extinguishers; and (2) determine whether the
Afghan government is currently using the building, and, if not, work with the MOCI to develop a plan to utilize
the building.
We provided a draft of this report to the Department of Defense for review and comment. USFOR-A and USACE
provided written comments, which are reproduced in appendices II and III, respectively. USFOR-A partially
concurred with the first recommendation. Regarding 1a, USFOR-A stated that the “expansion joints were filled
in accordance with the project specifications and drawings,” and the command did not have to take any action.
However, as stated in this report, we found that TI did not fill all of the expansion joints with preformed filler
material, as the contract required. Regarding recommendation 1b, USFOR-A agreed that the installation of
lavatory sink piping and p-traps was not in accordance with contract requirements. However, the command
stated that despite the deficiency, the piping and traps were “fully functional and effectively prevent the
intrusion of sewer gas into occupied spaces.” Regarding recommendation 1c and 1d, USFOR-A agreed to notify
the MOCI that insulation is needed around hot water pipes and that the counterfeit fire extinguishers should be
replaced. We will keep recommendation 1 open until USFOR-A provides documentation showing that it has
notified the MOCI of these construction deficiencies.
USFOR-A did not concur with the second recommendation. USFOR-A stated that it has transferred the building
to the Afghan government, and it is the Afghan government’s responsibility to determine the “appropriate and
timely use” of the building. The command did not indicate that it would take any action to work with the Afghan
government to develop a plan to use the $3.5 million building. As a result, upon issuance of this report, we will
close recommendation 2 as not implemented.
USACE said it was neither concurring nor non-concurring with the recommendations because they were
directed to USFOR-A. However, USACE provided technical comments, which we incorporated into the report, as
appropriate.
SIGAR conducted this inspection under the authority of Public Law No. 110-181, as amended, and the
Inspector General Act of 1978, as amended; and in accordance with the Quality Standards for Inspection and
Evaluation, published by the Council of the Inspectors General on Integrity and Efficiency.




John F. Sopko
Special Inspector General
   for Afghanistan Reconstruction
                                            TABLE OF CONTENTS



TI Generally Built the MOCI Replacement Building According to Contract Requirements, but Four
Construction Deficiencies Remain ............................................................................................................................. 1 
The MOCI Replacement Building Has Not Been Used, but Has Been Maintained .................................................. 5 

Conclusion.................................................................................................................................................................... 5 
Recommendations ...................................................................................................................................................... 6 
Agency Comments ....................................................................................................................................................... 6 

Appendix I - Scope and Methodology ......................................................................................................................... 8 
Appendix II - Comments from U.S. Forces–Afghanistan ............................................................................................ 9 
Appendix III - Comments from the U.S. Army Corps of Engineers ........................................................................... 11 

Appendix IV - Acknowledgments ............................................................................................................................... 15 


FIGURE

Figure 1 - Required Design of Sink, P-Trap, and Waste Pipe .................................................................................... 3 


PHOTOS

Photo 1 - MOCI Replacement Building ....................................................................................................................... 1 
Photo 2 - Unfilled Expansion Joint Between Columns and Beams Located Above Replacement
Building’s Ceiling ......................................................................................................................................................... 2 
Photo 3 - Noncompliant Sealant Placed in an Expansion Joint ................................................................................ 3 
Photo 4 - Sealant Used Was Manufactured by a Company Located in Iran............................................................. 3 
Photo 5 - Noncompliant Corrugated Plastic Tube Loosely Connected from Bathroom Sink to the Waste Pipe .... 4 

Photo 6 - Trap for Sinks in the Basement Below the Bathroom Floor ...................................................................... 4 




SIGAR 20-30-IP/Ministry of Commerce and Industries Replacement Building                                                                                              Page iii
ABBREVIATIONS

              FAR                        Federal Acquisition Regulation
              MOCI                       Ministry of Commerce and Industries
              TI                         Technologists Inc.

              USACE                      U.S. Army Corps of Engineers
              USFOR-A                    U.S. Forces–Afghanistan




SIGAR 20-30-IP/Ministry of Commerce and Industries Replacement Building        Page iv
On September 27, 2016, the U.S. Army Corps of Engineers (USACE) awarded a $3.2 million firm-fixed-price
contract to Technologists Inc. (TI), a U.S. company, to design and construct a building for the Afghan Ministry of
Commerce and Industries (MOCI) in Kunduz Province. This new building replaced an MOCI building that a U.S.
airstrike damaged on October 3, 2015. At the
time of the airstrike, the MOCI leased the             Photo 1 - MOCI Replacement Building
building to Spinzar Company Kunduz, an Afghan
government-controlled entity, and Médecins
Sans Frontières (also known as Doctors without
Borders), which operated in the building. In
January 2016, the Afghan government requested
that U.S. Forces–Afghanistan (USFOR-A)
reconstruct the building to its former condition.
The project called for the management, design,
material, labor, and equipment to construct a
complete building, including connections to
existing utilities. The design and construction
work was also to include clearing mines and
unexploded ordinance, demolishing and
removing all debris, and conducting a
geotechnical investigation and a topographical         Source: USACE, February 19, 2019
site survey, with the result being a fully usable
and functioning building (see photo 1).
USACE issued a notice to proceed on December 11, 2016, directing TI to begin work, and expected TI to
complete the project by September 2, 2018. USACE modified the contract three times, which increased the
contract’s value to $3.5 million and extended the completion date to October 14, 2018. USACE transferred the
project to USFOR-A on June 22, 2018, and the 1-year construction warranty period started that day. However,
USFOR-A did not formally accept the building until approximately 9 months later, and the Afghan MOCI
accepted the new building on March 20, 2019.
The objectives of this inspection were to determine whether (1) the construction was completed in accordance
with contract requirements and applicable construction standards, and (2) the facilities are being used and
maintained.1
We conducted our work in Kabul and Kunduz, Afghanistan, from October 2018 through January 2020, in
accordance with the Quality Standards for Inspection and Evaluation, published by the Council of the
Inspectors General on Integrity and Efficiency. Our professional engineers conducted the engineering
assessment in accordance with the National Society of Professional Engineers’ Code of Ethics for Engineers.
Appendix I contains a detailed discussion of our scope and methodology


TI GENERALLY BUILT THE MOCI REPLACEMENT BUILDING ACCORDING TO
CONTRACT REQUIREMENTS, BUT FOUR CONSTRUCTION DEFICIENCIES REMAIN

We made two site visits to the MOCI replacement building in February 2019, and a follow-up visit in August
2019.2 We found that TI generally constructed the building according to contract requirements. However, we
identified five construction deficiencies, including one that created a safety hazard. The construction
deficiencies involved (1) building expansion joints that were not filled with the required material, (2) p-traps
that were improperly installed under all the sinks, (3) hot water pipes that were not insulated, (4) counterfeit

1 We did not inspect all activities required by the contract, such as work to clear mines and unexploded ordinance. Our
inspection focused on the construction and use of the building.
2 We visited the MOCI replacement building on February 19 and 21, 2019, and August 3, 2019.



SIGAR 20-30-IP/Ministry of Commerce and Industries Replacement Building                                              Page 1
fire extinguishers, and (5) electrical cable identification tags that were missing.3 These deficiencies resulted
from TI not following the contract requirements, including technical specifications and design drawings, and
USACE not providing adequate project oversight. Further, neither USACE nor USFOR-A properly followed the
transfer, acceptance, and warranty procedures.
On May 20, 2019, we provided USACE a list of the deficiencies so it could direct TI to take corrective action
before the warranty period ended on June 22, 2019. USACE provided us with a written response stating that it
would direct TI to correct four of the five deficiencies. On June 27, 2019, USACE provided us with photos and
stated that TI corrected the deficiencies, except for the uninsulated hot water pipes. Before the August site
visit, USACE provided responses and actions it would direct TI to make. However, the contractor either did not
completely address the deficiencies we identified or did not comply with the contract requirements, because
during our August 3, 2019, site visit, we found that TI only installed identification tags for the electrical cables
and did not address the four remaining deficiencies.


TI Did Not Fill the Building Expansion Joints with the Required Material

The contract required TI to use preformed filler
material in concrete structural expansion joints        Photo 2 - Unfilled Expansion Joint Between Columns and
throughout the MOCI replacement building.               Beams Located Above Replacement Building’s Ceiling
Unless the proper material is placed in the
expansion joints, structural concrete elements,
such as columns, slabs, and beams, are likely
                                                             Unfilled Expansion
to exert force against each other during regular            Joint between Beams
environmental occurrences in Kunduz
Province, such as earthquakes, or expansions
and contractions caused by variations in                                                            Suspended
temperature. This could damage the building.                                                          Ceiling
Further, unfilled or improperly filled expansion
joints can cause leaks that ruin the building’s
interior.                                                   Unfilled Expansion
                                                          Joint between Columns
In June 2017, USACE approved TI’s submittal
for the required filler material used for the
expansion joints. However, during our February
21, 2019 site visit, we found that TI did not fill
                                                        Source: SIGAR, February 21, 2019
the expansion joints as required (see photo 2).
In June 2019, USACE told us the deficiency we identified existed in two sections of the building that move
independently. As such, the required joint material would not provide any structural benefit, even though the
contract required it. Nevertheless, that same month, USACE provided us with photos and stated that TI filled
the expansion joints. During our August 3, 2019, site visit, we found that TI placed noncompliant material in
the expansion joints (see photo 3). TI used a general-purpose sealant, commonly known as “caulking material,”
which is normally used for sealing small cracks or openings around windows and doors (see photo 4). Further,
we discovered that the general-purpose sealant was manufactured by Ghaffari Chemical Industries
Corporation, an Iranian company. Because Iran is subject to U.S. economic sanctions, this purchase violates
the Federal Acquisition Regulation (FAR).4


3 A p-trap is a U-shaped section of pipe that holds water and prevents foul gas in plumbing drains and sewers from rising up
through a toilet, sink, or floor drain into a building.
4 The FAR prohibits U.S. government contractors from obtaining goods and services from Iranian companies without

authorization from the Department of the Treasury’s Office of Foreign Assets Control. See FAR 52.225-13, Restrictions on
Certain Foreign Purchases, June 2008.

SIGAR 20-30-IP/Ministry of Commerce and Industries Replacement Building                                             Page 2
 Photo 3 - Noncompliant Sealant Placed in an                Photo 4 - Sealant Used Was Manufactured by a
 Expansion Joint                                            Company Located in Iran




     Expansion Joint with
    Noncompliant Sealant
      Between Columns


 Source: SIGAR, August 3, 2019                               Source: SIGAR, August 3, 2019


TI Did Not Adhere to the Design Requirements for Installing the P-Traps

The contract’s design drawings complied with International
Plumbing Code requirements and called for TI to install p-        Figure 1 - Required Design of Sink, P-Trap,
traps within 24 inches below all 20 sinks in the MOCI             and Waste Pipe
replacement building before making the air and water-tight
connection to the waste pipe (see figure 1). However, during
our February 2019 site visits, we found that TI did not install
p-traps in the required location. In addition, TI installed
noncompliant plastic corrugated flexible tubes that did not
create an air-tight seal between the tubes and the vertical
waste pipe to prevent foul gases from entering the
bathrooms (see photo 5).                                                                                 Sink

In June 2019, USACE stated that TI installed the p-traps for
the 20 sinks below the bathroom floors, extending into the
                                                                                                P-Trap
basement. During our August 2019 site visit, we found the p-
traps installed below the bathroom floors, but we determined
that they exceeded the 24-inch limited required by the
International Plumbing Code and the design drawings (see
photo 6).




                                                                   Source: TI’s submitted as-built drawing.
                                                                   Note: All measurements are in millimeters.




SIGAR 20-30-IP/Ministry of Commerce and Industries Replacement Building                                         Page 3
    Photo 5 - Noncompliant Corrugated Plastic Tube Loosely       Photo 6 - Trap for Sinks in the Basement Below
    Connected from Bathroom Sink to the Waste Pipe               the Bathroom Floor

                           Missing P-Trap                                           P-Traps One Floor
                                                                                    below the Sinks
      Noncompliant Corrugated
      Flexible Plastic Tube

       Connection to
       Waste Pipe
       Without Air-tight
       Seal




    Source: SIGAR, August 3, 2019                                 Source: SIGAR, August 4, 2019


TI Did Not Install Insulation on the Building’s Hot Water Pipes
The contract required TI to insulate all hot water pipes in the MOCI replacement building. During our February
19, 2019, site visit, we found that TI did not install any insulation on the hot water pipes as required. In June
2019, USACE stated that it would require TI to install the insulation. However, USACE told us in June 2019 that
TI would likely not fulfill the requirement to install the insulation because of the dangerous security situation in
Kunduz. At the time of our August 2019 site visit, TI still had not installed the required insulation.
The lack of insulation does not necessarily result in safety or maintenance issues. However, without the
insulation, hot water in the pipes will not maintain its temperature from the point of origin—the hot water
heater—to the desired location—taps or faucets.


TI Installed Counterfeit Fire Extinguishers
The contract required TI to install 12 fire extinguishers in the MOCI replacement building. During our February
2019 site visits, we found that 13 of the 14 fire extinguishers installed by TI had a “Buckeye” label with the
same serial number.5 We determined that these extinguishers were counterfeit because Buckeye Fire requires
each of its fire extinguishers to have a unique serial number. In June 2019, USACE told us that it would confirm
the deficiency and direct TI to replace the 13 counterfeit fire extinguishers with authentic fire extinguishers,
each with a different serial number. However, during our August 2019 site visit, we found that TI only replaced
10 of the 13 counterfeit fire extinguishers and left 3 counterfeit fire extinguishers. Counterfeit fire
extinguishers create a safety hazard because they may not work as intended when a fire occurs. For example,
counterfeit extinguishers have been known to contain unknown substances that do nothing to suppress fires,
as well as having pressure gauges that give false readings.




5The “Buckeye” label is supposed to denote a Buckeye Fire Equipment product. See Buckeye Fire Equipment Product
Catalog, 2017.

SIGAR 20-30-IP/Ministry of Commerce and Industries Replacement Building                                       Page 4
USACE and USFOR-A Did Not Follow Proper Transfer, Acceptance, and Warranty
Procedures
USACE–Afghanistan’s District Level Quality Assurance Plan for Construction states that, “the transfer of
construction to the using service will be simultaneous with the acceptance of that construction from the
contractor.”6 USACE determined that the MOCI replacement building was ready to be transferred to USFOR-A
on June 22, 2018, but USFOR-A did not formally accept the building until April 1, 2019. A USFOR-A official told
us that the U.S. and Afghan governments did not meet regarding the building’s transfer until November 2018,
or about 5 months after USACE transferred the project to USFOR-A. Although both governments tried to
schedule a subsequent follow-up meeting, what USFOR-A described as “prior commitments that were deemed
more valuable” delayed the follow-up until March 2019. Even though USFOR-A did not formally accept the
building from USACE until April 1, 2019, it inappropriately transferred the building to the MOCI for occupancy
and use on March 20, 2019.
In addition to not following transfer and acceptance procedures, USACE initiated the project’s 1-year warranty
period on June 22, 2018, which would expire in June 2019. The contract referenced FAR 52.246-21, Warranty
of Construction, which states that the warranty shall continue for a period of 1 year from the date of final
acceptance of the work, and USFOR-A did not formally accept the building until April 1, 2019.7 As such, the
MOCI only received approximately 3 months of warranty coverage to the building and its systems.
We found that from July 3, 2018, through March 21, 2019, the U.S. government paid more than $250,000 for
security and maintenance services at the MOCI replacement building. The Afghan government would have paid
these costs had formal turnover occurred on June 22, 2018. Thus, the delayed turnover procedure resulted in
more costs to the American taxpayer.


THE MOCI REPLACEMENT BUILDING HAS NOT BEEN USED, BUT HAS BEEN
MAINTAINED

During our August 2019 site visit, we found that the MOCI replacement building has not been used since TI
completed it in June 2018. In October 2019, we followed up with USFOR-A to determine whether the building
was in use, but as of the date of this report, USFOR-A has not provided an update.
During our February and August 2019 site visits, we did not find any maintenance issues with the replacement
building. As previously noted, the U.S. government paid to maintain the building for more than 9 months. The
MOCI is now responsible for securing and maintaining the building.


CONCLUSION

TI generally complied with contract requirements when completing the MOCI replacement building. However,
four construction deficiencies exist due to TI’s contract noncompliance and USACE’s inadequate oversight.
However, because USACE initiated the warranty period approximately 9 months before USFOR-A and the MOCI
accepted the completed facility, the warranty has expired, and TI is no longer responsible for correcting these
deficiencies. As of June 2019, the MOCI is responsible for any repairs and other work at the replacement
building. Finally, although the replacement building was completed in June 2018, the building had not been
used through at least August 2019. Because USFOR-A has not responded to our inquiry, we do not know
whether the building is currently in use.



6 USACE, Afghanistan Engineer District, District-Level Quality Assurance Plan for Construction, updated December 15,

2008, p. 30.
7 FAR 52.246-21, Warranty of Construction, April 1984.



SIGAR 20-30-IP/Ministry of Commerce and Industries Replacement Building                                           Page 5
RECOMMENDATIONS

To protect the U.S. taxpayers’ investment in the MOCI replacement building, we recommend that the
Commander of U.S. Forces–Afghanistan
    1. Notify the MOCI of the replacement building’s construction deficiencies so MOCI can take whatever
       action it deems appropriate to

             a.   fill the expansion joints with proper sealant,
             b.   install p-traps in the correct location,
             c.   insulate the hot water pipes, and
             d.   replace the counterfeit fire extinguishers.
    2. Determine whether the Afghan government is currently using the building, and, if not, work with the
       MOCI to develop a plan to utilize the building.


AGENCY COMMENTS

We provided a draft of this report to the Department of Defense for review and comment. USFOR-A and USACE
provided written comments, which are reproduced in appendices II and III, respectively. USFOR-A partially
concurred with the first recommendation and did not concur with the second recommendation. USACE said it
was neither concurring nor non-concurring with the recommendations because the recommendations were
directed to the Commander of USFOR-A. USACE also provided technical comments, which we incorporated into
the report, as appropriate.
Regarding recommendation 1a, USFOR-A stated that the “expansion joints were filled in accordance with the
project specifications and drawings,” and the command did not have to take any action. However, as stated in
this report, we found that TI did not fill all of the expansion joints with preformed filler material, as the contract
required. USACE agreed and required TI to fill the expansion joints with filler material. In its effort to correct the
deficiency, TI not only used the wrong type filler, but used a filler brand that is produced in Iran; this violates
the FAR because Iran is subject to U.S. economic sanctions. Although USFOR-A did not specifically address the
need to fill the expansion joints with proper filler or the use of the Iranian filler brand, USACE generally stated
that any non-compliant material should be removed from expansion joints and replaced with preformed filler in
expansion joints consistent with the design plans and specifications.
Regarding recommendation 1b, USFOR-A agreed that the installation of lavatory sink piping and p-traps was
not in accordance with contract requirements. However, the command stated that despite the deficiency, the
piping and traps were “fully functional and effectively prevent the intrusion of sewer gas into occupied spaces.”
Regarding recommendations 1c and 1d, USFOR-A concurred and stated that the command would notify the
MOCI that insulation is needed around the hot water pipes and recommend that the counterfeit fire
extinguishers be replaced.
USFOR-A stated that it is not its responsibility to correct the deficiencies because the MOCI accepted the
replacement building in March 2019, and the warranty expired in June 2019. We agree and did not indicate
that the deficiencies are USFOR-A’s responsibility. We maintain, however, that it is in USFOR-A’s interest to
notify the MOCI of the deficiencies to help ensure the Afghan government receives the full benefit of the U.S.-
funded project. We will keep recommendation 1 open until USFOR-A provides documentation showing that it
has notified the MOCI of these construction deficiencies.
We commend USACE for taking action to address the deficiencies we found during this inspection. For
example, to address the restriction on certain foreign purchases prohibited by FAR 52.225-13, such as the


SIGAR 20-30-IP/Ministry of Commerce and Industries Replacement Building                                        Page 6
sealant that TI purchased from Iran and used to fill the expansion joints, USACE stated that it would issue a
construction bulletin reminding its field staff, local national quality assurance representatives, and contractors
about the clause.
USFOR-A did not concur with recommendation 2. Although USFOR-A confirmed that the Afghan government has
never used the MOCI replacement building, the command stated that the President of Afghanistan requested
the building and that it is the Afghan government’s responsibility to determine the building’s appropriate and
timely use. USFOR-A did not indicate that it would any action to work with the Afghan government to develop a
plan to use the $3.5 million building. As a result, upon issuance of this report, we will close recommendation 2
as not implemented.




SIGAR 20-30-IP/Ministry of Commerce and Industries Replacement Building                                     Page 7
APPENDIX I - SCOPE AND METHODOLOGY

This report provides the results of SIGAR’s inspection of the Afghan Ministry of Commerce and Industries
(MOCI) replacement building in Kunduz Province. The objectives of this inspection were to determine whether
(1) the construction was completed in accordance with contract requirements and applicable construction
standards, and (2) the facilities are being used and maintained. Specifically, we
       reviewed contract documents, design submittals, and other relevant project documentation;
       interviewed U.S. Forces–Afghanistan, U.S. Army Corps of Engineers, and MOCI officials concerning the
        project’s construction, use, and maintenance; and
       conducted site visits to the replacement building on February 19 and 21, 2019, and August 3, 2019.
We did not rely on computer-processed data in conducting this inspection. However, we considered compliance
with laws and indicators of fraud, other illegal acts, and abuse, and their potential impact.
In December 2014, SIGAR entered into a cooperative agreement with Afghan civil society partners. Under this
agreement, our Afghan partners conduct specific inspections, evaluations, and other analyses. In this regard,
Afghan engineers inspected the replacement building in February and August 2019. We developed a
standardized engineering evaluation checklist covering items required by the contract. The checklist required
our partners to analyze the contract documents, scope of work, technical specifications, and design drawings.
We compared the information our Afghan civil society partners provided to accepted engineering practices,
relevant standards, regulations, laws, and codes for quality and accuracy. In addition, as part of our monitoring
and quality control process, we
       met with our Afghan partner engineers to ensure that the approach and planning for the inspection
        were consistent with the objectives of our inspection and the terms of our cooperative agreement;
       attended periodic meetings with our partners, and conducted our normal entrance and exit
        conferences with agency officials;
       discussed significant inspection issues with our partners;
       monitored our partners’ progress in meeting milestones and revised contract delivery dates as
        needed; and
       conducted oversight of our partners in accordance with SIGAR’s policies and procedures to ensure
        that their work resulted in impartial, credible, and reliable information.
We conducted our inspection work in Kabul and Kunduz, Afghanistan, from October 2018 through January
2020, in accordance with Quality Standards for Inspection and Evaluation, published by the Council of the
Inspectors General on Integrity and Efficiency. Our professional engineers conducted the engineering
assessment in accordance with the National Society of Professional Engineers’ Code of Ethics for Engineers.
We believe that the evidence obtained provides a reasonable basis for our findings and conclusions based on
our inspection objectives. We conducted this inspection under the authority of Public Law No. 110-181, as
amended, and the Inspector General Act of 1978, as amended.




SIGAR 20-30-IP/Ministry of Commerce and Industries Replacement Building                                   Page 8
APPENDIX II - COMMENTS FROM U.S. FORCES–AFGHANISTAN




SIGAR 20-30-IP/Ministry of Commerce and Industries Replacement Building   Page 9
SIGAR 20-30-IP/Ministry of Commerce and Industries Replacement Building   Page 10
APPENDIX III - COMMENTS FROM THE U.S. ARMY CORPS OF ENGINEERS




SIGAR 20-30-IP/Ministry of Commerce and Industries Replacement Building   Page 11
SIGAR 20-30-IP/Ministry of Commerce and Industries Replacement Building   Page 12
SIGAR 20-30-IP/Ministry of Commerce and Industries Replacement Building   Page 13
SIGAR 20-30-IP/Ministry of Commerce and Industries Replacement Building   Page 14
APPENDIX IV - ACKNOWLEDGMENTS

Steven Haughton, Senior Inspection Manager
Madeline Krahn, Inspector-in-Charge
Charles DeCarlo, Senior Auditor
Abdul Rahim Rashidi, Management Analyst
Yogin Rawal, General Engineer
Shahanshah Shirzay, Civil Engineer




SIGAR 20-30-IP/Ministry of Commerce and Industries Replacement Building   Page 15
                                       This inspection was conducted
                                      under project code SIGAR-I-059.




SIGAR 20-30-IP/Ministry of Commerce and Industries Replacement Building   Page 16
                               The mission of the Special Inspector General for Afghanistan
           SIGAR’s Mission     Reconstruction (SIGAR) is to enhance oversight of programs for the
                               reconstruction of Afghanistan by conducting independent and
                               objective audits, inspections, and investigations on the use of
                               taxpayer dollars and related funds. SIGAR works to provide accurate
                               and balanced information, evaluations, analysis, and
                               recommendations to help the U.S. Congress, U.S. agencies, and
                               other decision-makers to make informed oversight, policy, and
                               funding decisions to:
                                           improve effectiveness of the overall reconstruction
                                            strategy and its component programs;
                                           improve management and accountability over funds
                                            administered by U.S. and Afghan agencies and their
                                            contractors;
                                           improve contracting and contract management
                                            processes;
                                           prevent fraud, waste, and abuse; and
                                           advance U.S. interests in reconstructing Afghanistan.


  Obtaining Copies of SIGAR    To obtain copies of SIGAR documents at no cost, go to SIGAR’s Web
                               site (www.sigar.mil). SIGAR posts all publicly released reports,
   Reports and Testimonies     testimonies, and correspondence on its Web site.




                               To help prevent fraud, waste, and abuse by reporting allegations of
To Report Fraud, Waste, and    fraud, waste, abuse, mismanagement, and reprisal, contact SIGAR’s
      Abuse in Afghanistan     hotline:
   Reconstruction Programs                 Web: www.sigar.mil/fraud
                                           Email: sigar.pentagon.inv.mbx.hotline@mail.mil
                                           Phone Afghanistan: +93 (0) 700-10-7300
                                           Phone DSN Afghanistan: 318-237-3912 ext. 7303
                                           Phone International: +1-866-329-8893
                                           Phone DSN International: 312-664-0378
                                           U.S. fax: +1-703-601-4065



                               Public Affairs Officer
              Public Affairs               Phone: 703-545-5974
                                           Email: sigar.pentagon.ccr.mbx.public-affairs@mail.mil
                                           Mail: SIGAR Public Affairs
                                            2530 Crystal Drive
                                            Arlington, VA 22202