Navigating the Denton Program

Sanctioned Program

The Denton Program was created by Senator and former Vietnam Prisoner of War, Jeremiah Denton in an amendment to the Foreign Assistance Act of 1961. He understood the need for humanitarian assistance in developing third-world countries and in 1985 his amendment was implemented.

Denton Program is a Department of Defense (DoD) transportation program that moves humanitarian cargo, donated by U.S. based Non-Governmental Organizations (NGOs) to developing nations to ease human suffering. The approved cargo is transported by DoD land, air or sea assets on a space-available basis. The program is authorized by statute (10 U.S. Code 402) and is managed by the U.S. Department of State and Department of Defense. 

Generally, the program is not designed or intended for the transport of private sector commodity donations to disaster areas -- where civil systems, local infrastructure or logistics resources may be compromised due to a natural or civil disaster. In such cases, USAID, DoS and DoD will review the circumstances in the destination country, and the application, to determine whether or not a commodity donation should be transported by DAP to the area of the disaster.

Interagency Involvement
The actual transportation portion of this program is contractually managed by USTRANSCOM utilizing a contractor operating out of Joint Base Charleston, SC. The program is jointly administered by USAID, the Department of State (DOS), the Defense Security Cooperation Agency (DSCA) and the Department of Defense (DoD); although DSCA is the primary agency responsible for administering the program. USAID reviews applications to ensure they meet foreign policy objectives and that the donation meets a legitimate humanitarian need in line with country specific requirements.

10 USC 402 - Transportation of Humanitarian Relief Supplies to Foreign Countries
The federal law and source regulation that authorizes the manner by which the U.S. military can perform humanitarian airlift flights.

One of the first things we must do, to get started, is to locate a charity organization in need of Denton Program airlift. Perhaps there's a charity out there that has a Christian mission in Central America, or the Caribbean then that's okay. To qualify for Denton Program shipment the humanitarian cargo must be delivered outside the United States and its territories. Mind you, there are further restrictions of locations where Denton cargo can be received such as most of Africa and Asia, but ultimately the viability will depend on whether the location is supportable by the U.S. military airlift system, and considered to have a favorable political status with  the U.S. government. 

A Knight or Dame will need to reach out to either a known charity organization requiring assistance, or will need to establish a new relationship with a charity organization in need of our services. Remember, we are the facilitators to this process. Strictly limit your participation to educating, connecting, coordinating, and facilitating the activities surrounding charity and airbase operations relative to the Denton Program. We are not in the business of collecting donations, or even packaging, but rather to serve as a guide in order that we may help charities navigate the Denton Program such that one day they can operate independently by themselves. Our goal is to help charities to be able to do this on their own thus freeing up our time investment so that we may shift our time to start another. 

Locating a charitable organization may be as simple as going to your own church and asking whether they are involved in any foreign mission work that needs humanitarian assistance. Neither does an charity have to have an overseas mission to participate. If they are willing to collect humanitarian items, then these items can be combined with an organization that does and can be shipped. For example, your local Catholic diocese could decide to help the Chaldean Church in Iraq. The Chaldeans do have an established mission there and would be receiving that aid from a group that they are not affiliated with. Of course, it is always easier to work with an organization that already has an established mission “in country”, but it is not a show stopper.

Determine who the key decision makers are and introduce yourself and our organization. Let them know how OKF can be of assistance. The “hook” that will often capture them is that the program is secure and free. In contrast, commercial shipments via container ships, and subsequently overland trucking, are neither secure or free. For example, an 8k lbs. shipment from the U.S. to Iraq costs around $12,000 (USD) and no surprise that this (the money) is often the largest hurdle that many non-profits struggle to overcome. 

Deliver the presentation to the key decision makers. Reiterate the aforementioned advantage(s) of cost (none) and security. Again, that is your strongest “selling” point. If the organization has been making shipments overseas (not using the Denton Amendment Program), they will likely be very eager to get on board. Familiarize yourself with the processes outlined in the other lessons (presented here) and be prepared to answer questions. Assuming shipping location and cargo suitability, you can begin the next step.

Log onto the https://hatransportation.ohasis.org website, register the organization, obtain a login, and then begin completing the tabbed online forms in the application.  The first 5 tabs (from left to right as you are looking at the application) are easy and self-explanatory. The “consignee” (3rdtab) and the “country project manager” (5th tab) are usually the same person. Tabs 6-11 are detailed later in the Online Application lesson.

Consider Public Relations (PR) opportunities. Don't overlook the fact that all participating parties (to include the military and OKF) can realize tremendous promotional benefits from an orchestrated media plan. Don't forget that many military installations have Public Affairs offices and have further access to military "Combat Camera" units that can deploy, or requisition media support in the country where deliveries are made. Videos, photos, and articles relative to the entire Denton process and can, and do, help develop public interest and support for the Denton Program, the military, the charity's endeavor, and OKF. Don't forget that beyond the use of traditional media outlets, you can wisely use Social Media outlets to better promote your charity's story to particular audiences using targeted messaging. In any regard, please coordinate with the military and the charity before publicizing. If you have questions, refer to the OKF staff for clarification. 

Keep in mind also that one of the major functions of OKF is not only getting the word out about this great program, but also just as important, is to instruct in its proper use. The introductory PowerPoint presentation, should be used to share and familiarize your intended audience with the provisions of the Denton Program. Unfortunately, most charities - and even many stateside military organizations - are unfamiliar with the provisions of the Denton Program, much less, how it works. Indeed, as an OKF participant Knight, or Dame, you too are learning your way in, but eventually you will get good at guiding and advising your charity organization, and perhaps enlighten some military units along the way. Fortunately for us, the Denton program has a proven track record, is pretty straight forward in its application, and has reasonably well documented guidelines.

Jointly review, with your charity organization, shipping and cargo logistics with due consideration to program restrictions and limitations; process compliance is essential.  

The Denton Program is not for religious, or political material, troop donations, crisis response, soccer balls & toys, expired food or expired medical supplies.

Since the Denton Program is a space available program, no guarantees can be made regarding availability of transportation, or completion of, a shipment. The program is active in most areas of the world but it is more difficult to obtain transportation to more distant countries. Transportation has been most frequently available to Afghanistan, Iraq, Kazakhstan, Central America, South America, the Caribbean, and Djibouti (subject to diplomatic dynamics). Transportation to some Asian countries can be provided on a case-by-case basis. The Denton Program does not [usually] provide transportation to Africa except Djibouti. 

• A legitimate need for the supplies by the people for whom they are intended

• Supplies must be used for humanitarian purposes and consistent with U.S. foreign policy

• The beneficiaries are capable of using the donated commodities safely

• It must be in usable condition

Basic Requirements: Minimum weight: 2000 pounds. Maximum weight: 100,000 pounds; requests outside these parameters will not be accepted as follows:

•  The total number of pieces, the total gross weight (pounds) and total gross volume (cubic feet) of the cargo must be included on the application to permit DoD to determine transportation requirements.

• The total gross weight number is extremely important and needs to be as accurate as possible (within +/- 2%) -- transportation of your cargo may be delayed because of weight inaccuracies and any additional weight could be eliminated from your shipment. 

• Attach a complete itemized inventory of the cargo to be shipped, including a detailed listing by item of quantity, size (volume), and weight. It is recommended that you develop and maintain an itemized contents list per box/container/crate -- this will expedite the U.S. Government's inspection process and customs clearance in the destination country (in certain countries/instances, an itemized listing by container has been required).

• Very large shipments should be separated into several smaller shipments that can be more easily handled, on a space available basis. Very large shipments, and those including vehicles, take significantly longer to find transport and you, the donor, must be ready to determine a priority, if partial shipments are made.

• The addition of new items to the inventory, or increase the weight of the cargo to be shipped once the application has been submitted, is not permitted. Both U.S. Government and host country approval for these shipments are based on the information in the application. Shipping unapproved items or even additional quantities of approved items has caused embarrassment in the past and puts the entire Denton program in jeopardy. However, USAID, The Department of Defense, or their representatives reserve the right to remove items from the cargo – if this occurs, you will be notified.

Medical supplies are reviewed by USAID Staff Pharmacists with the Office of Foreign Disaster and Assistance. All medical supplies must be declared as sterile or nonsterile. Expiration dates are REQUIRED on all sterile items or items involved in invasive bodily procedures at least 18 months from the date of your application. Failure to disclose medical supplies will result in removal of those items from transport and possible inability to use the Denton Program any further.

• Drug donations will only be recommended for clearance if documentation of the consignee’s review and acceptance, denoted by consignee initialing of product manifest and a letter of acceptance and ability to utilize is included with the Denton application. In acute emergencies, review of manifest (by consignee) may be waived if consignee states, in an acceptance letter, general medical and pharmaceutical needs and willingness to accept donor’s gift of items responsive to those needs.

• All donated drugs or their generic equivalents should be approved for use in the recipient country and appear on the national list of essential drugs, or if a national list is not available, on the World Health Organization (WHO) Model List of Essential Drugs, unless specifically requested otherwise by the recipient. Exceptions may be made for products needed for outbreaks of uncommon or newly emerging diseases when products are not approved for use in country. 

• The presentation, strength and formulation of donated drugs should, as much as possible, be similar to those commonly used in the recipient country. 

• All donated drugs should be obtained from a reliable source and comply with quality standards in both donor and recipient countries. The majority of pharmaceutical products requested to be transported to a recipient country from a donor in the United States are Federal Drug Administration (FDA) approved; hence USAID does not require documentation certifying safety and effectiveness from donors wanting to send US-FDA approved products. Donors should specify that the products are FDA approved. For non-FDA approved products, the WHO Certification Scheme on the Quality of Pharmaceutical Products Moving in International Commerce should be submitted. 

• No drugs should be donated that have been issued to patients and then returned to a pharmacy or elsewhere, or were given to health professionals as free samples. 

• After arrival in the recipient country, all donated drugs should have remaining a shelf life of at least one year. For emergency situations (disaster declared countries, etc.), an exception may be made for direct donations to specific health facilities, provided a responsible professional at the receiving end is aware of the limited shelf life; and that the quantity and remaining shelf life allow for proper administration prior to expiration. In all cases, it is important that the date of arrival and the expiry dates of the drugs be communicated to the recipient well in advance. In such cases, written confirmation from the in-country recipient (via e-mail or facsimile transmission) documenting knowledge of the product’s limited dating but validating the need and ability to use the product prior to its expiration will be required. Otherwise, all products must have a minimum of one-year expiration dating upon arrival in the recipient country.

• All drugs should be labeled in a language that is easily understood by health professionals in the recipient country; the label on each individual container should at least contain the International Nonproprietary Name (INN) or generic name, batch number, dosage form, strength, name of manufacturer, quantity in the container, storage conditions and expiration date. USAID requires the submission of a subset of the information cited above. The required information should be provided in the manifest in a matrix/table format in the initial application requesting assistance with transport. 

• As much as possible, donated drugs should be presented in larger quantity units and hospital packs. This depends tremendously on the country and emergency situation. In many instances, unit-of-use containers may be a much more useful form of packaging for the health care providers to use. In other cases, if the product is going to a consignee (e.g. hospital) with the capabilities of repackaging, bulk containers may be appropriate (depending on if the consignee also has materials needed for repackaging). Documentation attesting to the consignee’s desires and needs is very important in determining appropriateness of container sizes. 

• All drug donations should be packed in accordance with international shipping regulations and be accompanied by a detailed packing list which specifies the contents of each numbered carton by INN, dosage form, quantity, batch number, expiration, volume, weight and any special storage conditions. The weight per carton should not exceed 50 kilograms (110 pounds). Drugs should not be mixed with other supplies in the same carton. EXTREMELY IMPORTANT! This packing list also serves as the manifest reviewed by OFDA pharmacists. A copy should be provided with submission of the Denton application and to the consignee for review and acceptance prior to the clearance process. Copies should be placed inside each carton describing the contents as well as affixed to the outside of each carton. This facilitates administration, storage, distribution, identification, and management of donated goods. 

• Donations will not be recommended for clearance until an in-country consignee capable of accepting, managing, and distributing the drug donation has been named and consignee states willingness to perform said functions. If consignee is not a direct member/associate of the health facility, which will receive and use the donation, the consignee should obtain this concurrence from the health facility.

• In the recipient country, the declared value of a drug donation should be based upon the wholesale price of its generic equivalent in the recipient country, or, if such information is not available, on the wholesale world market price for its generic equivalent.

Cargo Shipments Only: The Denton Program is limited to movement of cargo only, and the transportation of donor personnel and/or livestock is not authorized. 

• Donors should not list themselves as consignees or as playing a role in the distribution of the cargo at the final destination, with the expectation that the U.S. Government will transport them together with the cargo. 

• Donors who desire to be at the final destination in connection with receipt and/or distribution of the cargo must make alternative transportation arrangements. In this regard, the Department of Defense will make every effort to provide donor with timely information on arrival dates at final destination for all approved cargo.

Food: All off-the-shelf canned or prepared foods must have an expiration date at least 18 months from the date of application.

Storage: Cargo will generally move from your closest airbase, or where DOD locates a space available flight. Donors must be able to store cargo at their expense until transportation becomes available. DAP should not be used when deadlines are required as it is a space available program. .

PROHIBITED ITEMS: The following items are STRICTLY prohibited: Pharmaceuticals, Medicines, Livestock, Hazardous Materials (liquids, paints, gases, batteries, etc.), and Perishable foods, Political or Religious Items. DOD reserves the right to remove any cargo deemed unsafe or inappropriate for transport.

Doing the homework (due diligence). 

Time spent learning how to properly  employ this program will save you from unnecessary strife and frustration: “Do-overs” are a waste of time! Determine the humanitarian need. When reaching out to potential DP  participant charities, learn about their current mission programs. Are  they already engaged in supporting a current humanitarian need? If so,  what specific materials are they currently shipping? Are they seasonal  in nature? Do intended materials have an expiration date? Are there any  special handling instructions? To learn more about cargo acceptability,  please visit the DP website, HA Transportation. If a charity doesn’t have  a current mission to support, query them as to how they might like to  get involved with an existing mission, or start one of their own.  

Verify that the charitable organization’s humanitarian cargo storage  facility is suitable, secure, accessible, and enduring. Ensure that their  storage arrangements provide for; 

1. cargo security against pilferage, 
2. protection against the elements, 
3. insurability, 
4. easy cargo preparation and movement (packaging, palletizing,  weighing, unloading and loading), 
5. physical accessibility to cargo for DP inspection,  
6. charity personnel accessibility, and  
7. is available for storage periods of 3-4 months (sometimes more)  to accommodate DP processing times and flight availability. 

After collecting all humanitarian materials or equipment, all items will be prepared for inspection and then transported to a designated airport/airbase for air-transport packaging on standardized 463L aluminum aircraft cargo pallets. Each of these aircraft pallets measure 84x104 inches, are capable of handling up to 10,000 lbs., and can measure up to 96-100 inches. Pallet netting is normally used to secure loose items onto the 463L pallet before on-loading onto a military aircraft.

Packaging

• In preparation for USAID cargo inspection at the donor storage location, the donor must ensure that general cargo is first packaged into unsealed, but strong, durable boxes and crates (stackable). Only after the cargo is inspected and receives final approval by USAID, containers - secured onto wooden pallets - should be built up to a height as specified (for the particular airlift aircraft) by Department of Defense officials, or an OKF staff member. 

• Upon cargo acceptance, by the DoD, at the point of embarkation, palletized cargo may be staged, or stored outside while awaiting air shipment. Keep in mind that this cargo may be subject to the effects of mildew, water damage, and/or insect infestations thus should be properly packaged with barrier type coverings, linings, or wrappings.

• The use of Standardized GMA (Grocery Manufacturers Association) wooden pallets is encouraged and facilitates forklift movements. These pallets measure 40"x48" and are designed to hold up to 4,600 lbs. of payload. Four (4) of these pallets will fit onto a standard 463L aircraft pallet. 

• Nominally, a standard (fully loaded) 463L aluminum aircraft pallet (with a load of 4 GMA pallets) will be secured by a "top-net" and will measure around 48" in height, and weigh up to 2,500 lbs.  

• If a combination of "side" and "top-nets" will be used to construct the 463L pallet load, then cargo height my extend from 96"-100" and may weigh up to 8,000 lbs.

• Specially built crates/containers, for larger pieces, must be built for forklift handling and not exceed the 40"x48" footprint as outlined above. 

• There should be no packaging overhang on any GMA pallet as this may limit access to aircraft 463L pallet tie-downs locations when being prepared for air shipment by base DoD personnel.

• For vehicles and motorized equipment, special processing will be required (see below)

 Vehicles and other motorized items (generators, etc.) require special preparation for shipment by DoD. 

• These items must be clean and in good operable condition. Dirty, inoperable, or leaking equipment will not be accepted for transport.

• To ensure maximum utility to the beneficiaries, vehicles should have less than 80,000 miles of service. Vehicles with more than 80,000 miles of service may not be accepted for shipment.

• Vehicles that require a specially trained operator will not be accepted for transport. 

• Specific regulations for the transportation of vehicles are developed by the U.S. Air Force and are dependent on exact method of transportation, safety of flight, and security concerns. 

• Contact, by a U.S. Government representative, will be made before vehicle(s) delivery to the port of embarkation (U.S. military airbase), which will provide specific instructions, which must be met in order to ship vehicle(s) on U.S. military aircraft. 

• Vehicles must have only ¼ tank of gas and be in sound condition, no leaks, and have sound tires. A detailed vehicle inspection form (available on the HA Transportation website) should be filled out to certify flight worthiness.

Inspection. Cargo inspections are conducted by a third-party agent as scheduled by the DAP administrator and only after the Denton Program application has been completed and submitted. 

• Depending on demand, inspectors may not be physically available for several weeks after application approval. OKF has two certified inspectors on staff.

• Non-compliance issues will be annotated by the inspector and will require correction prior to transport. 

• Cargo will be inspected for proper packaging and authorized humanitarian materials for air shipment. Historically, there have been other users that have tried to hide unapproved religious materials in their shipment only to jeopardize future access to the program and create international situations leading to cargo seizures. 

• Affix shipping labels when inspection complete

Labeling. Each and every container must be marked sequentially by number, for example: Container 1 of 20, Container 2 of 20, etc. 

• A final inventory using this numbering system, as an index, must be submitted to the Department of Defense prior to pick up of the cargo. 

• When final approval has been granted, USAID will request the Department of Defense to make transportation arrangements. The Department of Defense will provide you a Transportation Control Number (TCN) number that is unique to that shipment. This number is assigned to assist the Defense Transportation System in tracking the cargo as it is transported to its destination. 

• The TCN must be stenciled or marked clearly on each box or item of the cargo in indelible ink.