The management of the Department of Homeland Security "is exposing employees to an extremely hazardous situation that can result in serious injury or even death by not providing and/or replacing personal protective equipment in the form of body armor," reads the complaint to the Occupational Safety and Health Administration of the U.S. Department of Labor.

Charles Showalter, president of the National Homeland Security Council of the American Federation of Government Employees, the labor union that filed the complaint, told United Press International that he believed on the basis of feedback from his members that "several thousand" employees of the department were affected.

The National Homeland Security Council represents about 16,000 employees in three elements of the department -- Customs and Border Protection; Immigration and Customs Enforcement; and U.S. Citizenship and Immigration Services.

Showalter said the main problem was with Customs and Border Protection employees working at ports of entry as inspectors, wearing uniforms and side-arms. He said federal regulations and departmental policy required that any officer issued a firearm should also be issued body armor.

"This is ... doing homeland security on the cheap," he said, "and the guys on the front lines are being forgotten and put in danger."

The complaint says the union has tried several times to raise the issue with management, but had recieved "no appropriate response."

Officials from Immigration and Customs Enforcement and Customs and Border Protection said they had not seen the complaint and could not comment on it directly.

Immigration and Customs Enforcement Spokeswoman Jamie Zuieback said new agents were issued body armor upon graduation from the Federal Law Enforcement Training Center, and that agency regulations prohibited uniformed personnel from taking part in law enforcement actions unless they were wearing it.

Lynn Hollinger, a spokeswoman for Customs and Border Protection said "The safety of our officers is of utmost importance," adding that the agency was "working to ensure that all officers have effective body armor."

But e-mails from union members around the country provided to UPI by Showalter show that in several places employees had been measured for armor, sometime more than once, but not issued it.

"We were required to turn in our (old) body armor because it was supposed to be 'deficient,'" wrote one. "I have not yet received replacement armor and go on duty everyday on the northern border with no body armor."

In 2003, armor made by Michigan, Ill.-based Second Chance Body Armor, Inc. had to be recalled after it was found that the artificial fiber from which it was made was degrading much faster than expected.

Zuieback said Immigration and Customs Enforcement operated a national tracking system, through which officers could order replacement armor in advance of a forthcoming expiry date.

Neither Showalter nor the agencies were able to offer exact figures on the extent of the problem, but UPI saw e-mails from dozens of officers complaining about delays or non-issuance.

"This is my third year and nothing," wrote another officer. "I have been in two separate incidents where if things had gone wrong I wouldn't be here today because I didn't have body armor."

"God forbid someone should be hurt or killed" because they didn't have the proper equipment, said Showalter. "How would the (officer's) family feel about that?" he asked.

Showalter said he knew of no officers injured because of not being issued body armor, but added that department was not properly reporting injuries to Customs and Border Protection officers through the FBI's Uniform Crime Reporting Program.

The department's management, he said "does not want to recognize (Customs and Border Protection) officers at ports of entry as real law enforcement officers."

He said another example of the attitude was that such officers were not eligible for the special law enforcement retirement provision referred to as "6(c) benefits."

"These officers are held to the same standards, have the same responsibilities, use the same equipment, as a law enforcement officer," he said, "Why are they not entitled to the same benefits?"

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