January 27, 2022

Allegation of Unauthorized Derivative Classifier Reviewing Documents

In the interest of national security, documents and material must be classified, declassified, downgraded, or upgraded only by individuals with appropriate authorities.  Although a reviewing official (RO) is an individual authorized to determine whether a document or material contains Unclassified Controlled Nuclear Information in specific subject areas and jurisdictions, a derivative classifier (DC) is an individual authorized to confirm that an unmarked document or material is classified or unclassified.  A DC must be nominated, trained, and appointed in writing by the Classification Officer.  Los Alamos National Laboratory Procedure P204–3, Classification of Matter, defines the requirements for classifying documents and material.  It states that newly generated or existing unmarked material in classified subject areas must be reviewed by a DC.  Also, only DCs are permitted to conduct classification reviews.  However, on June 30, 2021, the Department of Energy’s Office of Inspector General received an anonymous complaint that a Triad National Security, LLC employee (herein referred to as “Employee”) at Los Alamos National Laboratory (LANL) was impersonating a DC/RO for over a year.  We initiated this inspection to determine whether the alleged Triad National Security, LLC Employee at LANL was authorized to review and mark documents as a DC/RO.  We substantiated the allegation that a Triad National Security, LLC Employee at LANL reviewed and marked documents as a DC/RO even though the Employee was not an authorized DC/RO.  LANL also found that the Employee violated LANL P204–3, Classification of Matter, Section 3.2, Derivative Classifiers, when the Employee acted as a DC/RO without the required training or authorization.  While LANL took corrective action, we attributed this incident to unofficial DC/RO lists, weaknesses in the annual security training course, insufficient staffing in the Classification Office at LANL, and an inadequate testing universe during classification decision reviews.  Management fully concurred with our findings and recommendations, and they provided corrective actions taken and in process that are responsive to our recommendations.