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The Federal Bureau of Prisons'
Control Over Weapons and Laptop Computers

Report No. 02-30
August 2002
Office of the Inspector General

FINDINGS AND RECOMMENDATIONS

II. MANAGEMENT CONTROLS

We assessed management controls at the five BOP sites we visited:  the BOP Central Office, the Northeast Regional Office, the USP Lewisburg, the Federal Correctional Institution (FCI) Texarkana, and the BOP Federal Law Enforcement Training Center (FLETC) at Glynco, Georgia.  We identified areas that should be addressed either to improve efficiency or deter potential loss:

Automated Property Management Systems

Purchases

Receipt and Assignment

Disposal

We assessed the BOP’s compliance with OMB Circular A-123 and Federal Property Management Regulations, as well as Department and BOP guidance.  Our review included an evaluation of the controls over property management activities related to weapons and laptop computers at the Central Office and four field locations.  Specifically, we evaluated the existence and use of automated property management systems and reviewed the procedures for purchases, receipt and assignment, physical inventories, and disposal of accountable weapons and laptop computers.  In addition, we tested on a sample basis the accuracy and reliability of the BOP property records.  The universe of weapons and laptop computers assigned to the locations we audited is displayed in Appendix IV, Table 1.  We reviewed a total of 443 items, as summarized in the following table and detailed in Appendix IV, Table 2.

TOTAL ITEMS REVIEWED
ITEM CENTRAL OFFICE FCI TEXARKANA NORTHEAST REGIONAL OFFICE USP LEWISBURG FLETC/ GLYNCO TOTALS
WEAPONS 22 33 24 47 80 206
LAPTOP COMPUTERS 126 11 29 23 48 237
TOTALS 148 44 53 70 128 443

As of August 27, 2001, the BOP identified approximately 20,600 weapons and 2,700 laptop computers as being in active service. 16  The BOP Correctional Services Manual currently authorizes only 10 different weapons that can be issued to BOP personnel, not including the chemical fogger.  We noticed multiple listings for similar items in the inventory database provided to us by the BOP.  For instance, there were 388 "handguns," 578 "handgun, 38 cal," and 7,904 "handgun 9 mm."  However, 9 mm semi-automatic pistols in either single/double action or double action only modes are the only handguns that are currently authorized for use by BOP staff.  While we cannot determine if the 388 "handguns" are authorized, we do not believe the 578 "handgun, 38 cal" are authorized.  BOP property management regulations require that excess property (defined by the BOP as ". . . personal property not needed by the holding facility") be destroyed or donated, depending on the worth of the property and the need for that property by other government agencies.  The 578 "handgun, 38 cal" appear to be excess property.  In our judgment, the BOP should dispose of all weapons that are not authorized for use and can be considered excess property.  (See Appendix IV, Table 5 for a summary of BOP weapons by type.)

Automated Systems

The SPMS is the official property management system for controlled personal property and is used throughout the BOP to account for weapons and laptop computers.  Correctional facilities also use the AITS to identify the exact location of each weapon in the facility.  The AITS is not integrated with or reconciled to the SPMS, and access is strictly limited to armory Security Officers in each correctional facility.  The FLETC was not provided a copy of the AITS because the FLETC is not a correctional facility.  However, in our judgment, FLETC needs an automated system such as the AITS to identify the location of weapons by the Federal Prison System Identification (FPS ID) number assigned to them.  FLETC has the largest weapons inventory of any BOP facility.  Without utilizing the knowledge of the individual currently appointed APO of weapons, it is virtually impossible to locate any weapon at the FLETC by its FPS ID number (required during each annual inventory).

It also came to our attention that the size of the data entry field in the SPMS for the serial number of a property item is not sufficient to capture needed information.  Currently, the field only contains 12 digits.  As a result, serial numbers up to 15 digits long were being truncated to fit in this field.  Therefore, the serial number listed in the SPMS cannot be relied upon to positively identify property.

Purchases

BOP’s procurement of weapons and laptop computers is decentralized.  Each BOP facility has the authority to purchase weapons and laptop computers using either standard acquisition (purchase orders) or simplified acquisition procedures (government credit card).  Currently, the BOP has three national contracts for weapons17 and one national contract for computers.  If BOP seeks to buy weapons covered by the national contract, it must do so using that contract; it cannot buy the weapon using the simplified acquisition procedures.  Similarly, facilities may go outside of the computer contract to obtain laptop computers with requirements, but only if they cannot be met on the national contract.

When a laptop computer or weapon is received, the transaction should be entered into the property management and financial management systems.  Information about the property should be entered into a property management system in order to assign accountability for that item and monitor its location.  The Property Officer enters information about weapons and laptop computers into the SPMS when the items are received.

Financial information should be entered into a financial management system to ensure that budget constraints are met and that accurate information is collected to prepare the financial statements. Information about weapons and laptop computers purchased by the BOP is entered into the BOP’s Financial Management Information System (FMIS II)18 by the facility’s business office.

To ensure that accountable items that the BOP ordered, received, and paid for are being adequately monitored by property management personnel, the property and financial management systems should be reconciled at least once each year and preferably on a quarterly basis.  This reconciliation is consistent with the Joint Financial Management Improvement Program (JFMIP), Property Management Systems Requirements,19 OMB Circular A-123, and the JPMR that require reasonable assurance that assets are safeguarded and records are accurate and complete.  (Note that the JPMR does not specify any dollar limitation for this reconciliation.)  Currently, the two systems are not reconciled20 because the FMIS II cannot segregate data at the required level of detail.21

We judgmentally selected 53 weapons and 111 laptop computers from vendor invoices to determine if they were included in the SPMS.  Details of our sample, by location, appear in the following table.

ITEMS SELECTED FROM PURCHASE DOCUMENTS
PROPERTY TYPE CENTRAL FCI TEXARKANA NORTHEAST REGIONAL OFFICE USP LEWISBURG FLETC TOTAL
WEAPONS 6 0 0 17 30 53
LAPTOPS 75 0 10 9 17 111
TOTALS 81 0 10 26 47 164
Source:  OIG

Our tests revealed that 163 of the 164 items were included in the SPMS (99 percent).  The single item that was not found in the SPMS was a pepper fog generator.  The armory Security Officers indicated that they did not consider this to be a weapon.  However, when we pointed out that other pepper fog generators were included in the inventory as tear gas foggers, they agreed to enter the item into the SPMS.

During our testing we noticed that while purchase orders for laptop computers were usually coded with the correct SOC code, weapons were often coded incorrectly.  In addition, no credit card purchased items were reposted from the credit card default SOC code to a code that properly identified the type of item purchased.  Unless SOC codes are entered correctly, a reconciliation of FMIS II and the SPMS cannot be based on SOC codes.

The use of government credit cards to purchase weapons poses an additional problem in that cardholders could physically purchase and take delivery of weapons outside of a BOP facility.  Although we found that credit cards were used to purchase weapons at the FLETC,22 none of these weapons were purchased offsite.  However, we believe that this practice increases the likelihood that weapons would not be entered into the SPMS, and poses an unacceptable risk to the public because weapons purchased in this manner might be outside of the control of a BOP facility.23

Receipt and Assignment

Each item of controlled personal property is entered into the SPMS as a separate property record.  A total of 23 characteristics may be added to the SPMS for each property item (19 are required entries), and the SPMS is capable of maintaining a history of each item during its lifetime with the BOP. These records are maintained in the SPMS even after the property has been disposed of.  Currently, the SPMS maintains approximately 10 years of disposed records.24

BOP procedures for receiving property and ensuring its timely entry into the SPMS rely on the cooperation between warehouse personnel and the Property Officer, as well as armory Security Officers at correctional facilities and the FLETC.  At correctional facilities, laptop computers should be delivered directly to the warehouse, and weapons to the armory.  Warehouse personnel identify which property is controlled personal property, make independent counts,25 prepare receiving documents, assign FPS ID numbers and affix FPS ID tags, 26 and prepare the required forms27 for the Property Officer to input property data into the SPMS.  The input forms must be signed by the custodial APO before the Property Officer will key an entry into the SPMS to ensure that the property reached its assigned location.  We found that this system works well and ensures timely entry of weapons and laptop computers into the SPMS.

Problems can arise in those instances where weapons or laptops can be received outside of an armory or warehouse.  We found certain circumstances that could lead to untimely entry of weapons and laptop computers in the SPMS:

We analyzed the segregation of the major duties of purchasing, receiving, and recording information in the SPMS.  We found that due to limited staffing, the Property Officer was performing two or three of these functions29 at four of the five sites we visited.  However, sufficient alternate controls, including multiple approvals for credit card purchases and stringent review of documentation to support these purchases, were in place to ensure that all property would be accurately accounted for.

The BOP tracks property that is transferred from one facility to another by using a dual signature/dual entry system.  According to BOP policy, the sending facility’s APO should prepare and sign a hand receipt (BP-100(44))30 and the Property Officer should enter the property in the SPMS as transferred-out when the items are shipped.  The receiving facility’s Property Officer should enter property as transferred-in when receipt is signed by the new APO.  The BOP requires that no property be in the "transferred out" stage during the last five days of each month to ensure that all capitalized property is associated with a facility when the monthly institutional general ledger balances are determined.  The Property Management Section queries the SPMS to determine what property is in transit just prior to the monthly close, and instructs the shipping facility to reenter that property on their books by transferring it back in.31 The Property Management Section applies this requirement on both capitalized and non-capitalized property even though only capitalized property is of concern.  Some facilities would time shipments to ensure that no property is in transit during that five-day period.  Other facilities would not key property as in-transit until the receiving facility acknowledged receipt.  Delaying the transfer-out until receipt is acknowledged undermines a valuable system control for accurately tracking property transfers.

APOs within the same facility conduct inter-office transfers by physically moving the property and preparing and signing documentation of the transfer.  Recording of the transfer in the SPMS depends upon the timely preparation of the transfer document, 32 and the forwarding of that document to the Property Officer for keying the change into the SPMS.  Property Officers told us that documentation for transfers of laptop computers within the facility was not always prepared timely, and that the transfer was often not identified until the annual inventory.

OIG’s Testing of Property Records - To test the accuracy and completeness of the property records, we attempted to verify physically the existence of selected weapons and laptop computers appearing in the SPMS.  In addition, we selected a judgmental sample of weapons and laptop computers found at each location reviewed and attempted to trace them to the SPMS.  In total, we physically sampled 279 items (153 weapons and 126 laptop computers), as shown in the following table.  Further details of our sample, by property type, location, and type of test, appear in Appendix IV, Tables 3 and 4.

RESULTS OF PHYSICAL INSPECTION
PROPERTY TYPE CENTRAL
OFFICE		 FCI
TEXARKANA		 NORTHEAST
REGIONAL
OFFICE		 USP
LEWISBURG		 FLETC TOTALS
WEAPONS
CHOSEN FOR
INSPECTION		 16 33 24 30 50 153
WEAPONS FOUND 16 33 23 29 50 151
PERCENT OF
WEAPONS
FOUND		 100% 100% 96% 97% 100% 99%
LAPTOPS
CHOSEN FOR
INSPECTION		 51 11 19 14 31 126
LAPTOPS FOUND 50 11 19 14 31 125
PERCENT OF
LAPTOPS
FOUND		 98% 100% 100% 100% 100% 99%
TOTAL ITEMS
CHOSEN FOR
INSPECTION		 67 44 43 44 81 279
TOTAL ITEMS
FOUND		 66 44 42 43 81 276
PERCENT OF
TOTAL ITEMS
FOUND		 99% 100% 98% 98% 100% 99%
Source:  OIG

We were unable to locate one laptop computer during a physical inspection at the Central Office.  We questioned the APO about the whereabouts of this item and were told that the laptop computer had been lost by an airline during travel, but that the APO had not reported the loss since the airline had agreed to replace the item.  The APO intended to simply substitute the replacement laptop computer for the lost item and update the property record with a new description.  The PMO acknowledged that the APO had not complied with property management policies and procedures.

We found a pepper ball fogger at the USP Lewisburg that did not have an FPS ID tag, and we were unable to identify this weapon in the SPMS.  We discussed this situation with the Emergency Preparedness Coordinator at the USP Lewisburg and learned that the Central Office Security Technology Office had sent this weapon to them.  The weapon was to be used for a 2-week trial period only, and was scheduled to be returned to the vendor. 

Additionally, the USP Lewisburg stored 292 weapons acquired by the Northeast Regional Office in 1987 due to simultaneous prisoner uprisings at the USP Atlanta and the FCI Oakdale.  We found that these weapons had not been test fired in many years although the BOP Correctional Services Manual states that all weapons that are not in towers, patrol vehicles, and buses must be test fired semiannually.  We saw a rifle that blew up when test fired years ago because the ammunition for that weapon was unreliable.  Furthermore, we found that 247 of these weapons were .38 caliber revolvers, which are no longer authorized for use by the BOP.  The weapons were stored in a disorganized manner and piled in crates. BOP personnel expressed concerns over using these weapons in their current state.  We discussed the condition of the weapons with officials of the Northeast Regional Office and the USP Lewisburg, and expressed our concerns. We received documentation prior to the end of the audit that these weapons had been destroyed.

Pooled Property - All weapons and laptop computers at the BOP are technically pooled because they are assigned to a location in the SPMS rather than to an individual.  At correctional facilities, we found that weapons were located in armories, towers, patrol vehicles, or control centers and were physically safeguarded using key locks, remote access control, cages, and continuous observation.  Weapons are temporarily assigned to correctional officers only to accomplish a specific task such as a hospital escort trip, bus transports, and target practice, or in an emergency situation.  We found weapons in several locations at the Central Office, with access controlled by a variety of methods including controlled office access, locked storage rooms, safes, and trigger locks.  Weapons are temporarily assigned only during emergency situations.  We found that the regulations promulgated by the BOP do not address the security of weapons located at the Central Office and other administrative offices, but, in our judgment, are adequate for correctional facilities.

Employees of the BOP safeguard laptop computers primarily by keeping offices locked overnight.  The BOP regulations do not specifically address the physical security of laptop computers when offsite, although they do address the security of information processed on them.

Through our discussions with armory Security Officers at correctional facilities, and custodians at the Central Office and the training facility, we found that the BOP tracks temporary assignments of weapons through the use of hand receipts.33  However, we found that APOs were not required to track temporary or semi-permanent assignments of laptop computers.  Despite this, we did find that hand receipts were being used to track assignments of laptop computers at three of the five sites we visited. 34

Specialized Equipment and Rapid Mobilization Teams – At the USP Lewisburg we encountered a rapid mobilization response team authorized to carry lethal weapons.  This team is known as a Special Operations Response Team (SORT).  The SORT weapons were maintained in a separate secured section of the main armory and were identified in the AITS as segregated for SORT team use.  The SORT weapons were not specifically identified as such in the SPMS.  We judgmentally selected 10 weapons and 2 laptop computers that were segregated for SORT use to determine if the items were listed in the SPMS.  All items were identified in the SPMS.

Separated Employees – DOJ Order 2110.41 states that the head of each organization is responsible for developing, maintaining, and distributing an accountable item checklist for employees to complete prior to their separation from the Department.35 The checklist should be designed to fit the specific requirements and needs of the organization.  The Order further requires that clearance procedures for separating employees include a step to surrender to the appropriate property management officer, or property custodian all government owned property, including equipment, firearms, and other controlled property.  This step must be listed on the checklist for separating employees, and both the separating employee and the property custodian must provide certification that the step was completed.

The BOP does not have a standard checklist for employees who are separating from service.  Instead, each site we visited had developed their own checklist that separating employees must complete before leaving the institution.  This was true for employees who were transferring to another BOP facility or Department component, retiring, or resigning. The checklist is commonly referred to as the "merry-go-round" list by BOP employees because the separating employee must visit each office listed on the checklist and perform the required steps.

We examined documentation supporting the separation of individuals since October 1, 1999, at all of the sites we visited to determine if checklists had been completed, and what steps were included on the checklist.  Only the FLETC included a procedure on their checklist to ensure that "computer equipment" was returned to the APO prior to separation.  Ironically, this is the only site where we found that an employee that transferred to another BOP facility had failed to return a laptop computer.36 Failure to include this procedure could lead to accountable property not being returned, or returned only when the property is determined to be missing during an annual inventory.

Physical Inventories

The BOP performs an annual physical inventory of all controlled personal property, including all weapons and laptop computers. The Property Management Section initiates the annual inventory by sending each facility its official property list.37  The CEO of each institution schedules the inventory, oversees the results, and reports the status towards completion through the Regional Offices to the PMO.  We reviewed documentation of the FY 2001 physical inventory and reconciliation at each of the sites we visited to determine if these activities were completed on time, 38 and whether there was adequate segregation of duties.  In general, the FY 2001 physical inventories and reconciliations were substantially completed within the time limits set by BOP regulations, and segregation of major duties was adequate.

Documentation of the physical inventory is entirely in paper format.  The APO performing the physical inventory lists the location where each item was found on a preprinted property register, and lists all missing or additional items found on an exception report.39 The custodial APO must then address the exceptions to reconcile the inventory.  The Property Officer assists with the reconciliation by attempting to match all items reported as missing to all items reported as added throughout the facility.  This can be a tedious procedure especially in the Central Office where exception reports for 58 of 135 locations were submitted for the FY 2001 inventory.  We asked Property Officers if this process would be simplified if exception reports were submitted in electronic format and then combined in a single database.  This would make matching of missing and added property a simple procedure, and the database could be used to track follow-up on unresolved items.  This process need not be integrated with the SPMS.  We received mixed responses to this suggestion with some Property Officers being extremely enthusiastic while some were comfortable with the status quo.  However, we encourage the BOP to consider this option to simplify and shorten the reconciliation process.

Disposals

Disposals include any method in which a laptop computer or weapon may leave the custody of the BOP, including destruction, or donation to other Department components, federal, state, local, or private institutions.40  Before weapons or laptop computers may be declared as excess to BOP needs, the respective Board of Survey must make a determination that the property is of sufficient worth to be donated, or if not of sufficient worth, the manner in which it should be destroyed.  This determination is documented on a Report of Survey.  BOP regulations further specify that laptop computers should be cleaned of all sensitive information prior to disposal,41 and the property officer may not complete the disposal until confirmation of that step is received.

Laptop computers may be offered as excess property to other Department components and federal agencies, or may be donated directly to educational institutions.  Weapons may be donated either to other Department components, or offered to other federal, state, or local law enforcement agencies through the GSA Federal Surplus Supply Program.

We judgmentally selected a total of 22 disposals of weapons and 18 disposals of laptop computers occurring since October 1, 1999, and examined documentation to support each disposal.  Property Officers could not produce documentation supporting the removal of sensitive information from 8 of the 18 laptop computers we examined (44.4 percent), as detailed in the table below.  Controls could be improved on laptop disposals by including a line on the Report of Survey for Computer Services to attest that all sensitive information was removed from the hard drive.

TESTING OF DISPOSALS
SITE # EXAMINED
FOR WEAPONS		 INADEQUATE
DOCUMENTATION
FOR WEAPONS		 # EXAMINED FOR
LAPTOP
COMPUTERS		 INADEQUATE
DOCUMENTATION 42
FOR LAPTOP
COMPUTERS
Central Office 10 0 10 7
FCI Texarkana 1 1 43 0 44 0
Northeast Regional Office 0 44 0 2 0
USP Lewisburg 10 0 3 1
FLETC 1 0 3 0
TOTALS 22 1 18 8
PERCENT OF INADEQUATE DOCUMENTATION 4.5% 44.4%
Source:  OIG

We found one instance where the Property Officer did not witness the destruction of a weapon but was required to certify that the disposal had been accomplished.  Since the Property Officer must certify on the Report of Survey that disposal was accomplished in the manner prescribed by the Board, the Property Officer should be required to witness all disposals whether it be by donation or destruction.  In contrast to this case, the USP Lewisburg provided significant detail supporting the destruction of weapons, including pictures of the destruction and documentation of the disposal of parts in a landfill.

We also examined documentation to support the method of disposal entered in the SPMS for 506 weapons and 199 laptop computers as discussed in Finding I, Items Reported.

Conclusion

Our audit revealed weaknesses in the BOP’s management controls over weapons and laptop computers.  We found that the use of automated property management systems as well as policies and procedures for the purchase, receipt and assignment, and disposal of weapons and laptop computers could be improved to increase accountability for these items.

Recommendations

    We recommend that the BOP Director ensure that:

  1. Weapons that are no longer authorized for use and meet the definition of excess property be disposed.

  2. FLETC is provided with the AITS, or a similar database, that will enable it to locate weapons by FPS ID number.

  3. The field size for serial numbers is increased in the SPMS to accommodate a minimum of 15 digits.

  4. Procedures are developed to reconcile financial information entered in the FMIS II to the SPMS property entries for all controlled personal property, including weapons and laptop computers.

  5. The BOP acquisition regulations are modified to prohibit the use of government credit cards to purchase weapons.

  6. Weapons and laptop computers purchased by the Northeast Regional Office are delivered directly to the Property Officer instead of to sub-sites or the credit card purchaser.

  7. Personnel stationed at the gates of correctional facilities are properly instructed about weapon and laptop computer delivery procedures.

  8. Procedures are developed to ensure that laptops delivered to correctional facilities are routed directly to the warehouse.

  9. The Property Management Regulations are modified to:

    1. address the physical security of weapons at administrative offices,

    2. require that Property Officers witness the disposal of all controlled personal property.

  10. The Information Security Programs regulation is modified to address physical security of laptop computers used outside of BOP facilities.

  11. A standard checklist for separating employees is developed for use at all BOP facilities that includes a step to surrender all accountable property to the APO.

  12. Property Officers are instructed:

    1. that shipping should be timed to avoid transfer-outs during the monthly financial closing, rather than delay entry of transfer-outs in the SPMS; and

    2. to communicate to APOs the importance of documenting internal transfers and providing documentation to the Property Officer in a timely manner.

Footnotes

  1. To facilitate weapon identification, the BOP assigns a code for each type of weapon.  The BOP has 42 possible codes, but is using only 34 of them.  For example, item code 10501 indicates that the property item is a shotgun.

  2. The BOP has contracted for shotguns, and two different modes of 9 mm handguns.  Other types of authorized weapons may be purchased on the open market as long as they meet BOP specifications.

  3. FMIS II is the financial management system used throughout the BOP to record all financial data.

  4. JFMIP-SR-00-4 (October 2000).

  5. The two systems have a limited interface.  The FMIS II obtains data about capitalized personal property from the SPMS to capture information on assets reported in the financial statements.

  6. The level of detail is the sub-object classification (SOC) code.

  7. During the two-year period of our review, the FLETC used the government credit card twice to purchase a total of three weapons.

  8. Since we initially reported the finding to the BOP, it has taken initial steps to prohibit the use of the government credit card to purchase weapons.

  9. Records that are removed from the SPMS are archived.

  10. Armory Security Officers make independent counts of weapons and forward this information to the warehouse for completion of the steps for receipt of goods.

  11. Every item of controlled personal property is required to have an FPS ID tag affixed to it.  In addition, weapons are to have the FPS ID number etched onto them.  Laptop computers are not etched to avoid damage to the unit.

  12. The BP-S133.044 Input Transaction – Property Management System form lists all the information about a property item to create the property record in the SPMS. See Appendix VI [Not available electronically] for a sample of this form.

    14. Armories are always located outside the walls of a correctional facility.

  14. Four of the five Property Officers were government credit cardholders or were authorized to initiate purchase orders.

  15. A sample BP-100(44) is displayed in Appendix VII [Not available electronically].

  16. The Property Management Section contacts the Regional Office who in turn contacts the facility and instructs them to transfer property back in.

  17. A BP-100(44) is also used to record inter-office transfers.

  18. A sample of a hand receipt is displayed in Appendix VIII [Not available electronically].

  19. APOs at the Central Office and the Northeast Regional Office used hand receipts in the form of a BP-100(44).  The APO at FLETC used a computer database system to track assignments in addition to requiring self-designed hand receipts.  The Property Officer also annotated the name of the employee having more permanent custody in the Remarks section of the SPMS property record.

  20. Separation includes resignation, transfer, retirement, or any other type of separation from or reassignment within the Department.

  21. The Property Officer later completed the paperwork to transfer the laptop computer to the new facility.

  22. The list is derived from the SPMS and is broken down by locations within the facility.

  23. Annual physical inventories are performed each April and must be completed by April 30.  Reconciliation of the differences discovered must be completed by July 31.

    25. The exception report is known as a Report of Equipment Inventory Differences.  A sample is displayed in Appendix IX [Not available electronically].

  25. Property that is returned to the vendor is also considered to be disposed.  We did not encounter any returns in our testing.

  26. BOP procedures call for overwriting the data using utility programs that meet the Department of Defense Standard (DOD 5220.22M) and the DOS format “/U” switch version 6.20 and above.

  27. Documentation that hard drives had been wiped clean of sensitive information.

  28. Weapon was destroyed without witnesses or other documentation of destruction.

  29. No disposals occurred during this period.