[Title 32 CFR 751]
[Code of Federal Regulations (annual edition) - July 1, 2002 Edition]
[Title 32 - NATIONAL DEFENSE]
[Subtitle A - Department of Defense (Continued)]
[Chapter Vi - DEPARTMENT OF THE NAVY]
[Subchapter E - CLAIMS]
[Part 751 - PERSONNEL CLAIMS REGULATIONS]
[From the U.S. Government Printing Office]


32NATIONAL DEFENSE52002-07-012002-07-01falsePERSONNEL CLAIMS REGULATIONS751PART 751NATIONAL DEFENSEDepartment of Defense (Continued)DEPARTMENT OF THE NAVYCLAIMS
PART 751--PERSONNEL CLAIMS REGULATIONS--Table of Contents




               Subpart A--Claims Against the United States

Sec.
751.1 Scope of subpart A.
751.2 Claims against the United States: In general.
751.3 Authority.
751.4 Construction.
751.5 Definitions.
751.6 Claims payable.
751.7 Claims not payable.
751.8 Adjudicating authorities.
751.9 Presentment of claim.
751.10 Form of claim.
751.11 Investigation of claim.
751.12 Computation of award.
751.13 Payments and collections.
751.14 Partial payments.
751.15 Reconsideration and appeal.
751.16-751.20 [Reserved]

          Subpart B--Demand On Carrier, Contractor, or Insurer

751.21 Scope of subpart B.
751.22 Carrier recovery: In general.
751.23 Responsibilities.
751.24 Notice of loss or damage.
751.25 Types of shipments and liability involved.
751.26 Demand on carrier, contractor, or insurer.
751.27 Preparation and dispatch of demand packets.
751.28 Assignment of claimants rights to the government.
751.29 Recoveries from carrier, contractor, or insurer.
751.30 Settlement procedures and third party responses.
751.31 Common reasons for denial by carrier or contractor.
751.32 Forwarding claims files for offset action.
751.33 Unearned freight packet.
751.34 GAO appeals.
751.35 Forms and instructions.

    Authority: 5 U.S.C 301; 10 U.S.C. 939, 5013, and 5148; E.O. 11476, 3 
CFR, 1969 Comp., p. 132; 32 CFR 700.206 and 700.1202.

    Source: 57 FR 5055, Feb. 12, 1992, unless otherwise noted.



               Subpart A--Claims Against the United States



Sec. 751.1  Scope of subpart A.

    Subpart A of this part prescribes procedures and substantive bases 
for administrative settlement of claims against the United States 
submitted by Department of the Navy (DON) personnel and civilian 
employees of the naval establishment.



Sec. 751.2  Claims against the United States: In general.

    (a) Maximum amount payable. The Military and Civilian Employees' 
Personnel Claims Act (Personnel Claims Act), 31 U.S.C. 3701, 3702, and 
3721, provides that the maximum amount payable for any loss or damage 
arising from a single incident is limited to $40,000.00. Claims for 
losses occurring prior to 31 October 1988 are limited to $25,000.00.
    (b) Additional instructions. The Judge Advocate General of the Navy 
may issue additional instructions or guidance as necessary to give full 
force and effect to this section.
    (c) Preemption. The provisions of this section and the Personnel 
Claims Act are preemptive of other claims regulations. Claims not 
allowable under the Personnel Claims Act may, however, be allowable 
under another claims act.
    (d) Other claims. Claims arising from the operation of a ship's 
store, laundry, dry cleaning facility, tailor shop, or cobbler shop 
should be processed in accordance with NAVSUP P487.



Sec. 751.3  Authority.

    The Personnel Claims Act provides the authority for maximum payment 
up to $40,000.00 for loss, damage, or destruction of personal property 
of military personnel or civilian employees incident to their service. 
The Act provides for the recovery from carriers, warehouse firms, and 
other third parties responsible for such loss, damage, or destruction. 
No claim may be paid unless it is presented in writing within 2 years of 
the incident giving rise to the claim.



Sec. 751.4  Construction.

    The provisions of this section and the Personnel Claims Act provide 
limited compensation to service members and civilian employees of the 
DON for loss and damage to personal property incurred incident to 
service. This limited compensation is not a substitute for private 
insurance. Although not every loss may be compensated under the

[[Page 408]]

Personnel Claims Act, its provisions shall be broadly construed to 
provide reasonable compensation on meritorious claims. Adjudications 
must be based on common sense and the reasoned judgment of the claims 
examiner giving the benefit of realistic doubt to the claimant.



Sec. 751.5  Definitions.

    (a) Proper claimants--(1) Members of the DON. All Navy and Marine 
Corps active duty members and reservists on active duty for training 
under Federal law whether commissioned, enrolled, appointed, or 
enlisted. A retired member may only claim under this Act if loss or 
damage occurred while the claimant was on active duty or in connection 
with the claimant's last movement of personal property incident to 
service.
    (2) Civilian employees of the Navy. Federal employees of the naval 
establishment paid from appropriated funds. This term does not include 
Red Cross employees, USO personnel, and employees of Government 
contractors (including technical representatives).
    (3) Claims by nonappropriated-fund employees. Claims by employees of 
Navy and Marine Corps nonappropriated-fund activities for loss, damage, 
or destruction of personal property incident to their employment will be 
processed and adjudicated in accordance with this enclosure and 
forwarded to the appropriate local nonappropriated-fund activity which 
employs the claimant for payment from nonappropriated-funds.
    (4) Separation from service. Separation from the service or 
termination of employment shall not bar former military personnel or 
civilian employees from filing claims or bar designated officers from 
considering, ascertaining, adjusting, determining, and authorizing 
payment of claims otherwise falling within the provision of these 
regulations when such claim accrued prior to separation or termination.
    (b) Improper claimants. Insurers, assignees, subrogees, vendors, 
lienholders, contractors, subcontractors and their employees, and other 
persons not specifically mentioned as proper claimants.
    (c) Unusual occurrence. Serious events and natural disasters not 
expected to take place in the normal course of events. Two different 
types of incidents may be considered unusual occurrences: those of an 
unusual nature and those of a common nature that occur to an unexpected 
degree of severity. Examples of unusual occurrences include structural 
defects in quarters, faulty plumbing maintenance, termite or rodent 
damage, unusually large size hail, and hazardous health conditions due 
to Government use of toxic chemicals. Examples of occurrences that are 
not unusual include potholes or foreign objects in the road, ice and 
snow sliding off a roof onto a vehicle, and tears, rips, snags, or 
stains on clothing. Claims that electrical or electronic devices were 
damaged by a power surge may be paid when lightning has actually struck 
the claimant's residence or objects outside the residence, such as a 
transformer box, or when power company records or similar evidence shows 
that a particular residence or group of residences was subjected to a 
power surge of unusual intensity. In areas subject to frequent 
thunderstorms or power fluctuations, claimants are expected to use surge 
suppressors, if available, to protect delicate items such as computers 
or videocassette recorders.
    (d) Personal property. Property including but not limited to 
household goods, unaccompanied baggage, privately owned vehicles 
(POV's), mobile homes, and boats.
    (e) Intangible property. Property that has no intrinsic marketable 
value such as bankbooks, checks, promissory notes, non-negotiable stock 
certificates, bonds, baggage checks, insurance policies, money orders, 
and travelers checks.
    (f) Vehicles. Includes automobiles, motorcycles, mopeds, utility 
trailers, camping trailers, trucks, mounted camper bodies, motor homes, 
boats, boat trailers, bicycles, and aircraft. Mobile homes and other 
property used as dwelling places are not considered vehicles.



Sec. 751.6  Claims payable.

    Claims for loss, damage, or destruction of property may be 
considered as

[[Page 409]]

set out below if possession of the property was reasonable and useful 
under the circumstances and the loss did not result from the negligence 
of the claimant.
    (a) Transportation and storage losses. (1) Incurred during 
transportation under orders, whether in possession of the Government, 
carrier, storage warehouse, or other Government contractor.
    (2) Incurred during travel under orders, including temporary duty.
    (3) Incurred during travel on a space available basis on a military 
aircraft, vessel, or vehicle.
    (4) Do-it-yourself (DITY) moves. In certain circumstances, loss of 
or damage to property during a DITY move is compensable. Claimants, 
however, are required to substantiate the fact of loss or damage in 
shipment. Claimants who do not prepare inventories have difficulty 
substantiating thefts. In addition, unless evidence shows that something 
outside the claimant's control caused the damage, breakage is presumed 
to be the result of improper packing by the claimant. For example, if a 
claimant's truck is rear-ended by a drunk driver during a DITY move, it 
is out of claimant's control. If the claimant can substantiate that he 
was free from negligence, he can file a claim for damages to his 
household goods.
    (5) Shipment or storage at the claimant's expense. The shipment or 
storage is considered Government-sponsored if the Government later 
reimburses the claimant for it. The Government, however, will not 
compensate a claimant for loss or damage that occurs while property is 
being shipped or stored at the claimant's expense, even if the 
Government reimburses the claimant for the shipment or storage fees. The 
reason for this is that there is no contract, called a Government Bill 
of Lading (GBL), between Government and the carrier. In such cases the 
claimant must claim against the carrier.
    (b) Losses at assigned quarters or other authorized places. Damage 
or loss caused by fire, explosion, theft, vandalism, lightning, flood, 
earthquake, and unusual occurrences. Losses due to theft may only be 
paid if the claimant took reasonable measures to safeguard the property 
and the theft occurred as a result of a forced entry. Claimants are 
expected to secure windows and doors of their barracks, quarters, wall 
lockers, and other storage areas. Claimants are expected to store 
valuables in a secure area within their barracks, quarters, and storage 
areas. Claimants are also expected to take extra measures to protect 
cash, valuable jewelry, and similar small, easily pilferable items. 
Normally, such items should be kept in a locked container within a 
secured room. It is also advisable that the locked container be large 
enough that it is not convenient for a thief to carry off. Bicycles 
located at quarters or on base must be secured to a fixed object. 
Overseas housing is considered assigned quarters for claimants who are 
not local inhabitants.
    (c) Vehicle losses. (1) Incurred while a vehicle is used in the 
performance of military duty, if such use was authorized or directed for 
the convenience of the Government, provided the travel did not include 
commuting to or from the permanent place of duty, and did not arise from 
mechanical or structural defect of the vehicle. There is no requirement 
that the loss be due to fire, flood, hurricane, or other unusual 
occurrence, or to theft or vandalism. As a general rule, however, travel 
is not considered to be for the convenience of the Government unless it 
was pursuant to written orders authorizing use for which the claimant is 
entitled to reimbursement. The claimant must be free from negligence in 
order to be paid for a collision loss. Travel by the claimant to other 
buildings on the installation is not considered to be under orders for 
the convenience of the Government. Travel off the installation without 
written orders may only be deemed to be for the convenience of the 
Government if the claimant was expressly directed by his superior to use 
POV to accomplish the mission. The issuance of written orders after the 
fact raises the presumption that travel was not for the convenience of 
the Government. The maximum payment of $2,000.00 authorized by the 
Allowance List-Depreciation Guide still applies to loss of or damage to 
vehicles and contents. This maximum does not apply to DITY moves.

[[Page 410]]

    (2) Incurred while a vehicle is shipped at Government expense, 
provided the loss or damage did not arise from mechanical or structural 
defect of the vehicle during such shipment. Damage caused during 
shipment at the claimant's expense or while the vehicle is being moved 
to or from the port by an agent of the claimant is not compensable.
    (3) Incurred while a vehicle is located at quarters or other 
authorized place of lodging, including garages, carports, driveways, 
assigned parking spaces, if the loss or damage is caused by fire, flood, 
hurricane, theft, or vandalism, or other unusual occurrence. Vandalism 
is damage intentionally caused. Stray marks caused by children playing, 
falling branches, gravel thrown by other vehicles, or similar 
occurrences are not vandalism. The amount payable on vandalism claims is 
limited to $2,000.00.
    (4) Incurred while a vehicle is located at places other than 
quarters but on a military installation, if the loss or damage is caused 
by fire, flood, hurricane, theft, or vandalism, or other unusual 
occurrence. ``Military installation'' is used broadly to describe any 
fixed land area, wherever situated, controlled, and used by military 
activities or the Department of Defense (DOD). A vehicle properly on the 
installation should be presumed to be used incident to the claimant's 
service. A vehicle that is not properly insured or registered in 
accordance with local regulations is not properly on the installation. A 
vehicle left in a remote area of the installation that is not a 
designated long-term parking area for an undue length of time is 
presumed not to be on the installation incident to service.
    (5) Theft of property stored inside a vehicle. Claimants are 
expected to lock doors and windows. Neither the passenger compartment 
nor the trunk of a vehicle is a proper place for the long-term storage 
of property unconnected with the use of the vehicle. The passenger 
compartment of a vehicle does not provide adequate security, except for 
very short periods of time for articles that are not of high value or 
easily pilferable. Car covers and bras are payable if bolted or secured 
to the vehicle with a wire locking device.
    (6) Rental vehicles. Damage to rental vehicles is considered under 
paragraphs of the Joint Federal Travel Regulations (JFTR), rather than 
as a loss incident to service.
    (d) Mobile homes and contents in shipment. Claims for damage to 
mobile homes and contents in shipment are payable unless the damage was 
caused by structural or mechanical defects (see Sec. 751.12(g) below on 
mobile homes).
    (e) Borrowed property (including vehicles). Loss or damage to 
borrowed property is compensable if it was borrowed for claimant's or 
dependent's own use. A statement will be provided by the owner of the 
property attesting to the use of the property by the claimant.
    (f) Clothing and articles being worn. Repairs/replacement of 
clothing and articles being worn while on a military installation or in 
the performance of official duty may be paid if loss is caused by fire, 
flood, hurricane, theft, or vandalism, or other unusual occurrence. This 
paragraph shall be broadly construed in favor of compensation, but see 
Sec. 751.5(c) for the definition of unusual occurrence. Articles being 
worn include hearing aids, eyeglasses, and items the claimant is 
carrying, such as a briefcase.
    (g) Personal property held as evidence or confiscated property. If 
property belonging to the victim of a crime is to be held as evidence 
for an extended period of time (in excess of 2 months) and the temporary 
loss of the property will work a grave hardship on the claimant, a claim 
for the loss may be considered for payment. This provision will not be 
used unless every effort has been made to determine whether secondary 
evidence, such as photographs, may be substituted for the item. No 
compensation is allowed to a person suspected of an offense for property 
seized from that same person in the investigation of that offense. This 
also applies to property a foreign government unjustly confiscates or an 
unjust change in a foreign law that forces surrender or abandonment of 
property.
    (h) Theft from possession of claimant. Theft from the person of the 
claimant is reimbursable if the theft occurred by use of force, 
violence, or threat to do

[[Page 411]]

bodily harm, or by snatching or pickpocketing, and at the time of theft 
the claimant was either on a military installation, utilizing a 
recreation facility operated or sponsored by the Department of Defense 
or any agency thereof, or in the performance of official duty. The theft 
must have been reported to appropriate police authorities as soon as 
practicable, and it must have been reasonable for the claimant to have 
had on his person the quality and the quantity of the property allegedly 
stolen.
    (i) Property used for the benefit of the Government. Compensation is 
authorized where property is damaged or lost while being used in the 
performance of Government business at the direction or request of 
superior authority or by reason of military necessity.
    (j) Money deposited for safekeeping, transmittal, or other 
authorized disposition. Compensation is authorized for personal funds 
delivered to and accepted by military and civilian personnel authorized 
by the commanding officer to receive these funds for safekeeping, 
deposit, transmittal, or other authorized disposition, if the funds were 
neither applied as directed by the owner nor returned to the owner.
    (k) Fees--(1) For obtaining certain documents. The fees for 
replacing birth certificates, marriage certificates, college diplomas, 
passports, or similar documents may be allowed if the original or a 
certified copy is lost or destroyed incident to service. In general, 
compensation will only be allowed for replacing documents with a raised 
seal that are official in nature. No compensation will be allowed for 
documents that are representative of value, such as stock certificates, 
or for personal letters or records.
    (2) Estimate fees. An estimate fee is a fixed cost charged by a 
person in the business of repairing property to provide an estimate of 
what it would cost to repair property. An estimate fee in excess of 
$50.00 should be examined with great care to determine whether it is 
reasonable. A person becomes obligated to pay an estimate fee when the 
estimate is prepared. An estimate fee should not be confused with an 
appraisal fee, which is not compensable (see Sec. 751.7). A reasonable 
estimate fee is compensable if it is not going to be credited toward the 
cost of repair. If it is to be credited toward the cost of repair, it is 
not compensable regardless of whether the claimant chooses to have the 
work done. When an estimate fee is claimed, the file must reflect 
whether the fee is to be credited.



Sec. 751.7  Claims not payable.

    (a) Losses in unassigned quarters in the United States. Claims for 
property damaged or lost at quarters occupied by the claimant within the 
United States that are not assigned or otherwise provided by the 
Government.
    (b) Currency or jewelry shipped or stored in baggage. Claims for 
lost money, currency, or jewelry shipped or stored in baggage are not 
payable. Coin or paper money included in collections is payable only if 
listed on an inventory prepared at origin.
    (c) Enemy property or war trophies. This includes only property that 
was originally enemy property or a war trophy that passed into the hands 
of a collector and was then purchased by a claimant.
    (d) Unserviceable or Worn-Out Property.
    (e) Loss or Damage to Property to the Extent of any Available 
Insurance Coverage as Set Forth in Sec. 751.26 of this part.
    (f) Inconvenience or loss of use. Expenses arising from late 
delivery of personal property, including but not limited to the expenses 
for food, lodging, and furniture rental, loss of use, interest, carrying 
charges, attorney's fees, telephone calls, additional costs of 
transporting claimant or family members, time spent in preparation of 
claim, or cost of insurance are not compensable. While such claims do 
not lie against the Government, members should be referred to the 
Personal Property Office for assistance in filing their inconvenience 
claims against the commercial carriers (NAVSUP Publication 490, 
Transportation of Personal Property).
    (g) Items of speculative value. Theses, manuscripts, unsold 
paintings, or a similar creative or artistic work done by the claimant, 
friend, or a relative is limited to the cost of materials only. The 
value of such items is speculative.

[[Page 412]]

Compensation for a utilitarian object made by the claimant, such as a 
quilt or bookcase, is limited to the value of an item of similar 
quality.
    (h) Loss or damage to property due to negligence of the claimant. 
Negligence is a failure to exercise the degree of care expected under 
the circumstances that is the proximate cause of the loss. Losses due, 
in whole or in part, to the negligence of the claimant, the claimant's 
spouse, child, houseguest, employee, or agent are not compensable.
    (i) Business property. Losses of items acquired for resale or use in 
a private business are not compensable. If property is acquired for both 
business and personal use, compensation will not be allowed if business 
use is substantial, or is the primary purpose for which the item was 
purchased, or if the item is designed for professional use and is not 
normally intended for personal use.
    (j) Motor vehicles. Collision damage is not payable unless it meets 
the criteria for payment as property used for the benefit of the 
Government as established in Sec. 751.6(c)(1).
    (k) Violation of law or directives. Property acquired, possessed, or 
transported unlawfully or in violation of competent regulations or 
directives. This includes vehicles, weapons, or property shipped to 
accommodate another person, as well as property used to transport 
contraband.
    (l) Sales tax. Sales taxes associated with repair or replacement 
costs will not be considered unless the claimant provides proof that the 
sales tax was actually paid.
    (m) Appraisal fees. An appraisal, as distinguished from an estimate 
of replacement or repair, is defined as a valuation of an item provided 
by a person who is not in the business of selling or repairing that type 
of property. Normally, claimants are expected to obtain appraisals on 
expensive items at their own expense.
    (n) Quantities of property not reasonable or useful under the 
circumstances are not compensable. Factors to be considered are 
claimant's living conditions, family size, social obligations, and any 
particular need to have more than average quantities, as well as the 
actual circumstances surrounding the acquisition and loss.
    (o) Intangible Property, such as Bankbooks, Checks, Promissory 
Notes, Stock Certificates, Bonds, Bills of Lading, Warehouse Receipts, 
Baggage Checks, Insurance Policies, Money Orders, and Traveler's Checks 
are not Compensable.
    (p) Property Owned by the United States, Except where the Claimant 
is Responsible to an Agency of the Government other than the DON.
    (q) Contractual coverage. Losses, or any portion thereof, that have 
been recovered or are recoverable pursuant to contract are not 
compensable.



Sec. 751.8  Adjudicating authorities.

    (a) Claims by Navy personnel. (1) The following are authorized to 
adjudicate and authorize payment of personnel claims up to $40,000.00:
    (1) The Judge Advocate General;
    (ii) Deputy Judge Advocate General;
    (iii) Any Assistant Judge Advocate General;
    (iv) The Deputy Assistant Judge Advocate General (Claims and Tort 
Litigation); and
    (v) Commanding officers of Naval Legal Service Offices.
    (2) The Staff Judge Advocate attached to Naval Supply Center, 
Oakland is authorized to adjudicate and pay claims up to $25,000.00.
    (3) The Staff Judge Advocate attached to Naval Station, Panama Canal 
is authorized to adjudicate and pay claims up to $10,000.00.
    (4) The following are authorized to adjudicate and authorize payment 
of personnel claims up to $5,000.00:
    (i) Officers in charge of Naval Legal Service Office Detachments;
    (ii) The Staff Judge Advocate attached to Naval Station, Keflavik; 
and
    (iii) Any personnel attached to a Naval Legal Service Office when 
specifically designated by the commanding officer of that Naval Legal 
Service Office.
    (5) Any individual, when personally designated by the Judge Advocate 
General, may be authorized to adjudicate and authorize payment of 
personnel claims up to any delegated amount, not to exceed $40,000.00.
    (b) Claims by Marine Corps personnel. (1) The following individuals 
are authorized to adjudicate and authorize

[[Page 413]]

payment of personnel claims up to $40,000.00:
    (i) Commandant of the Marine Corps;
    (ii) Deputy Chief of Staff, Manpower and Reserve Affairs Department;
    (iii) Director, Human Resources Division;
    (iv) Head, Personal Affairs Branch;
    (v) Deputy Head, Personal Affairs Branch;
    (vi) Head, Personnel Claims Section; and
    (vii) Any individual, when personally designated by the Commandant 
of the Marine Corps, may be authorized to adjudicate and authorize 
payment of personnel claims up to any delegated amount, and not to 
exceed $40,000.00.
    (2) The following individuals are authorized to adjudicate and 
authorize payment of personnel claims up to $25,000.00:
    (i) Head, Adjudication Unit;
    (ii) Head, Carrier Recovery Unit; and
    (iii) Head, Administration Unit.



Sec. 751.9  Presentment of claim.

    (a) General. A claim shall be submitted in writing and, if 
practicable, be presented to the claims office or personal property 
office serving the installation where the claimant is stationed, or 
nearest to the point where the loss or damage occurred. If submission in 
accordance with the foregoing is impractical under the circumstances, 
the claim may be submitted in writing to any installation or 
establishment of the Armed Forces which will forward the claim to the 
appropriate Navy or Marine Corps claims office for processing. To 
constitute a filing under this regulation, a claim must be presented in 
writing to one of the military departments. Claims that are incomplete 
will not be refused and shall be logged in as received. Claimants 
submitting such claims, however, shall be informed in writing that 
properly completed forms or necessary substantiation must be received 
within a fixed period of time (normally 30 days), otherwise the claim 
will be denied or paid only in the amount substantiated.
    (b) Statute of limitations. A claim must be presented in writing to 
a military installation within 2 years after it accrues. This 
requirement is statutory and may only be waived if a claim accrues 
during armed conflict, or armed conflict intervenes before the 2 years 
have run, and good cause is shown. In this situation, a claim may be 
presented not later than 2 years after the end of the armed conflict. A 
claim accrues on the day the claimant knows or should know of the loss. 
For losses that occur in shipment of personal property, normally the day 
of delivery or the day the claimant loses entitlement to storage at 
Government expense (whichever occurs first) is the day the claim 
accrues. If a claimant's entitlement to Government storage terminates, 
but the property is later delivered at Government expense, the claim 
accrues on delivery. In computing the 2 years, exclude the first day 
(day of delivery or incident) and include the last day. If the last day 
falls on a non-workday, extend the 2 years to the next workday.
    (c) Substantiation. The claimant is responsible for substantiating 
ownership or possession, the fact of loss or damage, and the value of 
property. Claimants are expected to report losses promptly. The greater 
the delay in reporting a loss, the more substantiation the claimant is 
expected to provide.
    (1) Obviously damaged or missing inventory items that are not 
reported at delivery. Claimants are expected to list missing inventory 
items and obvious damage at time of delivery. Claimants who do not 
should be questioned. Obviously some claimants will simply not notice 
readily apparent damage. If, however, the claimant cannot provide an 
explanation or lacks credibility, payment should be denied based on lack 
of evidence that the item was lost or damaged in shipment.
    (2) Later-discovered shipment loss or damage. A claimant has 70 days 
to unpack, discover, and report loss and damage that is not obvious at 
delivery. In most cases, loss and damage that is discovered later and 
reported in a timely manner should be deemed to have been incurred in 
shipment.
    (3) Damage to POV's in shipment. Persons shipping POV's are expected 
to list damage on DD Form 788 (Private Vehicle Shipping Document for 
Automobile) when they pick up the vehicle. Obvious external damage that 
is not listed is not payable. Damage the claimant could reasonably be 
expected

[[Page 414]]

not to notice at the pickup point should be considered if the claimant 
reports the damage to claims personnel within a short time, normally a 
few days, after arriving at the installation.
    (4) Credibility. Most claimants are honest. Most claimants 
objectively attempt to claim only what is due them. These persons are 
entitled to the presumption that what they list is honest, although it 
may not be correct. Some claimants lack credibility and their claims 
require careful scrutiny. Factors that indicate a claimant's credibility 
is questionable include amounts claimed that are exaggerated in 
comparison with the cost of similar items, insignificant or almost 
undetectable damage, very recent purchase dates for most items claimed, 
and statements that appear incredible. Such claimants should be required 
to provide more evidence than is normally expected.
    (5) Inspections. Whenever a question arises about damage to 
property, the best way to determine a proper award is to examine the 
item closely to determine that nature of the damage. For furniture, 
undersurfaces and the edges of drawers and doors should be examined to 
determine whether the material is solid hardwood, fine quality veneer 
over hardwood, veneer over pressed wood, or other types of material. If 
the inspection is conducted at the claimant's quarters, the general 
quality of property should be determined. Claimants should routinely be 
directed to bring in vehicles and small broken items of value such as 
figurines for inspection, and inspections should be conducted on all 
large claims. Observations by repairmen and transportation inspectors 
are very valuable, but on occasion, claims personnel must go out of the 
office and inspect items themselves. Such inspections are necessary to 
reduce the number of reconsiderations and fraudulent claims and are 
invaluable in enabling claims personnel to understand the facts in many 
situations.



Sec. 751.10  Form of claim.

    The claim should be submitted on DD Form 1842 (Claim for Personal 
Property) accompanied by DD Form 1844 (List of Property). If DD Forms 
1842 and 1844 \1\ are not available, any writing will be accepted and 
considered if it asserts a demand for a specific sum and substantially 
describes the facts necessary to support a claim cognizable under these 
regulations. The claim must be signed by a proper claimant (see 
Sec. 751.5) or by a person with a power of attorney for a proper 
claimant. A copy of the power of attorney must be included with the 
claim.
---------------------------------------------------------------------------

    \1\ Copies of these forms may be obtained by contacting the claims 
office or personal property office serving the installation where the 
claimant is stationed, or nearest to the point where the loss or damage 
occurred.
---------------------------------------------------------------------------



Sec. 751.11  Investigation of claim.

    Upon receipt of a claim filed under the Personnel Claims Act, the 
claim shall be stamped with the date and receiving office, and be 
referred to a claims investigating officer. The investigating officer 
shall consider all information and evidence submitted with the claim and 
shall conduct such further investigation as may be necessary and 
appropriate.



Sec. 751.12  Computation of award.

    The Judge Advocate General will periodically publish an Allowance 
List-Depreciation Guide specifying rates of depreciation and maximum 
payments applicable to categories of property. The Allowance List-
Depreciation Guide will be binding on all DON claims personnel. The 
value of the loss is determined and adjusted to reflect payments, 
repairs, or replacement by carriers or insurers, or lost potential 
insurance or carrier recoveries.
    (a) Repair of items. For items that can be economically repaired, 
the cost of repair or an appropriate loss in value is the measure of the 
loss. The cost of repair may be the actual cost, as demonstrated by a 
paid bill, or reasonable estimated costs, as demonstrated by an estimate 
of repair prepared by a person in the business of repairing that type of 
property.
    (1) Loss of value (LOV)--(i) Minor damage not worth repairing. An 
LOV, rather than replacement cost, should be awarded when an item 
suffers minor

[[Page 415]]

damage that is not economical to repair but the item remains useful for 
its intended purpose. An LOV is particularly appropriate when the item 
is not of great value and has preexisting damage (PED). An LOV is also 
appropriate to compensate claimants for minor damage, such as a chip or 
surface crack to a figure or knickknack. For example, if an inexpensive, 
fiberboard coffee table with extensive PED is scratched, repair of the 
scratch would exceed the value of the table. Under the circumstances, 
LOV is appropriate.
    (ii) Damage to upholstered furniture. If damage can be repaired 
imperceptibly by cleaning or reweaving, the claimant is only entitled to 
repair cost. If repairs would be somewhat noticeable but the damage is 
to an area not normally seen, repair costs plus an LOV would be 
appropriate. Alternatively, if repairs would be somewhat noticeable but 
the item is of no great value and has already suffered PED, repair costs 
and LOV would be appropriate even if the damage is in an obvious area. 
If, however, repairs would be so noticeable as to destroy the usefulness 
of the item, the item should be reupholstered or replaced. What is 
noticeable will depend on the nature and value of the item, and the 
nature of the damage, and claims personnel should exercise sound 
judgment to avoid being too lenient or too harsh.
    (iii) Cosmetic damage to nondecorative items. LOV should also be 
awarded to compensate claimants for cosmetic damage to items that were 
not purchased for purposes of display or decoration. For example, the 
casing of a washing machine is dented. The washing machine is not 
decorative in nature and still functions perfectly. An LOV, rather than 
replacement of the washing machine or the casing, is the appropriate 
measure of the claimant's loss.
    (2) PED to repairable items. PED is damage to an item that predates 
the incident giving rise to a claim. PED is most commonly identified by 
the use of symbols on household goods shipment inventories. Whenever PED 
is listed on an inventory, claims personnel must determine whether the 
PED did in fact exist and whether the cost of repairing the item 
includes repairing PED. The fact that a claimant signed the inventory 
that listed PED is conclusive evidence that PED did exist unless the 
member has taken written exceptions on the inventory to the carrier's 
description of PED. These findings are essential for recovery purposes. 
Often inspecting the item or calling the repairman who prepared the 
estimate is the only way to make an effective determination.
    (i) Estimates that do not include repair of PED. If the estimate 
does not include repair of PED, even if PED is listed on the inventory, 
no deduction should be made. This fact should be recorded on the 
chronology sheet and on carrier recovery documents.
    (ii) Estimates that include repair of PED. If repair of PED is 
included in the estimate, the percentage attributable to repair of PED 
is deducted.
    (3) Mechanical defects. The Personnel Claims Act only provides 
compensation for losses incurred incident to service. Damage resulting 
from a manufacturer's defect or from normal wear and tear is not 
compensable. Damage to the engine or transmission of an old vehicle 
during shipment is probably due to a mechanical defect. Internal damage 
to appliances, such as old televisions, is also often due to a 
mechanical defect, particularly when their is no external damage to the 
item. Claims for internal damage to small appliances that are not 
normally repaired, such as toasters or hair dryers, should be assessed 
based on damage to other items in the carton and the shipment, the age 
of the item, the honesty of the claimant, and whether there are loose 
parts inside. If the evidence suggests rough handling caused the damage, 
a claim for the item should be paid. Internal damage to larger items 
such as televisions or stereos should be evaluated by a repairman. 
Evidence that suggests rough handling, such as smashed boards, provides 
a basis for payment. Evidence that suggests a fault in the item, such as 
burned-out circuits, does not. Deterioration because an item in storage 
was not used for a long time, rather than because the item was 
mishandled or the conditions of storage were improper, is also 
considered due to a mechanical defect.

[[Page 416]]

    (4) Wrinkled clothing. Clothing wrinkled in shipment presents 
special problems. Normally, unless the wrinkling is so severe as to 
amount to actual damage, the cost to press wrinkles out of clothing 
after a move is not compensable. The mere fact that clothing was 
``wadded up'' or ``used as packing material'' is not in itself 
sufficient. The wrinkling must be such that professional pressing is 
necessary to make the clothing usable. This determination will depend on 
the wrinkling and the nature of the material.
    (5) Wet and mildewed items. A claimant has a duty to mitigate 
damages by drying wet items to prevent further deterioration. Items that 
have been wet are not necessarily damaged and claimants who throw them 
away have difficulty substantiating that a loss has occurred. Although a 
deeply seated mildew infestation is almost impossible to remove 
completely, items lightly infested can often be cleaned.
    (b) Replacement of items. A claimant is entitled to the value of 
missing and destroyed items. An item that has sustained damage is 
considered destroyed if it is no longer useful for its intended purpose 
and the cost of repairing it exceeds its value. Value is measured in the 
following ways:
    (1) Similar used items. If there is a regular market for used items 
of that particular type, the loss may be measured by the cost of a 
similar item of similar age. Prices obtained from industry guides or 
estimates from dealers in this type of property are acceptable to 
establish value. There is a regular market on used cars and the value of 
a used automobile is always measured according to the N.A.D.A. Official 
Car Guide rather than the depreciated replacement cost. Similarly, the 
Mobile Home Manufactured Housing Replacement Guide may be used to value 
a destroyed mobile home. Where there is no regular market in a 
particular type of used item, however, estimates from dealers in 
``collector's items'' should be avoided.
    (2) Depreciated replacement cost. This is the normal measure of a 
claimant's loss. A catalog or store price for a new item similar in size 
and quality is depreciated using the Allowance List-Depreciation Guide 
to reflect wear and tear on the missing or destroyed item. The 
replacement cost for identical items--particularly decorative items--
should be used whenever the item is readily available in the local area, 
but a claimant who is eligible to use the Navy Exchange (NEX) and the 
NEX Mail Order Catalog should not be allowed a higher replacement cost 
of an item, such as a television, from a specialty store when the NEX 
carries an item comparable in size, quality, and features from another 
manufacturer.
    (3) ``Fair and reasonable'' (F&R) awards. A fair and reasonable 
award should be used sparingly when other measures would compensate the 
claimant appropriately. Overuse of such awards impedes carrier recovery 
and ``F&R'' should never be used when a more precise measure of damages 
is available. An F&R award for a missing or destroyed item should 
reflect the value of an item similar in quality, description, age, 
condition, and function to the greatest extent possible. An F&R award 
for a damaged item should reflect either the amount a firm would charge 
for repair or the reduced value to the greatest extent possible. 
Whenever such an award is made, the basis for the award should be 
explained on the chronology sheet, in the comments block of DD Form 1844 
(List of Property), or in a separate memorandum. A fair and reasonable 
award may be considered in the following instances:
    (i) The item is obsolete and a simple deduction of a percentage for 
obsolescence is not appropriate.
    (ii) The claimant cannot replace the item in the local area.
    (iii) The claimant cannot replace the item at any cost.
    (iv) Repair costs or replacement costs are excessive for the item 
and an LOV is not appropriate.
    (v) The claimant has substantiated a loss in some amount but has 
failed to substantiate a loss in the amount claimed.
    (c) Depreciation. The Personnel Claims Act is only intended to 
compensate claimants for the fair market value of their loss. Except in 
unusual cases, a used item that has been lost or destroyed is worth less 
than a new item of the same type. The price of a

[[Page 417]]

new replacement item must be depreciated to award the claimant the value 
of the lost or destroyed item. Average yearly and flat rates of 
depreciation have been established to determine the fair value of used 
property in various categories. These rates are listed in the Allowance-
List Depreciation Guide. The listed depreciation rate should be adjusted 
if an item has been subjected to greater or lesser wear and tear than 
normal or if the replacement cost the claimant provides is for a used 
item rather than a new one. Yearly depreciation is not taken during 
periods of storage and normally no depreciation is taken on repair costs 
or on replacement cost for items less than 6 months old, excluding the 
month of purchase and the month the claim accrued (but see 
Sec. 751.12(c)(3)).
    (1) Depreciating replacement parts. No depreciation should be taken 
on replacement parts for damaged items unless these are parts separately 
purchased or normally replaced during the useful life of these items. 
The replacement cost for these latter items should be depreciated. For 
example, the glass top to a table is not normally replaced during the 
useful life of the table and should not be depreciated.
    (2) Depreciating fabric for reupholstery. Fabric is normally 
replaced during the useful life of upholstered furniture. When 
upholstered furniture is reupholstered because the damage is too severe 
to be repaired and an LOV is not appropriate, the cost of new fabric is 
depreciated at a rate of 5 percent per year. If the item has been 
reupholstered since it was purchased, depreciation is measured from the 
date the item was last reupholstered, rather than from the date the item 
was originally purchased. Labor costs are allowed as claimed. If the 
estimate does not list separate costs for fabric and labor, the labor 
costs may be assumed to be 50 percent of the total bill.
    (3) Rapidly depreciating items. Tires, most clothing items, and most 
toys rapidly lose their value, as the high depreciation rate for these 
items reflects. Depreciation should be taken on such items even when 
they are less than 6 months old. As a rule of thumb, half of the normal 
yearly or flat rate depreciation should be taken on such items when they 
are between 3 and 6 months old at the time of loss.
    (4) Obsolescence. Even though depreciation is not taken during 
periods of storage, obsolescence should be claimed on those items that 
have lost value because of changes in style or technological 
innovations.
    (5) Military uniforms. Normally, no depreciation should be taken on 
military uniforms. Depreciation, however, should be taken on military 
uniform items that are being phased out or that belong to persons 
separating from the service. Socks and underwear are not considered 
military uniform items.
    (d) Salvage value. Whenever a claimant has been fully compensated 
for a destroyed item that still has some value, the claimant has the 
option of either retaining the item and having the claims office deduct 
an amount for the salvage value, or turning the item over to the 
Government or to the carrier if the carrier will fully reimburse the 
Government.
    (1) Turn-in to the Government. On all claims, except CONUS domestic 
shipments, if the claimant does not choose to retain the items and 
accepts a reduction in the amount paid on the claim for salvage value, 
the claims office will require the claimant to turn them into a disposal 
unit designated by the Personal Property Office. Normally, the amount 
that the Government may obtain from selling such items is very low. If 
the claims office determines that the salvage value is less than $25.00, 
the claimant may be advised to dispose of the items by other means, 
either by throwing the item away or by turning it over to a charitable 
organization. Claimants may also be directed to make alternative 
disposition of items that have been refused by the designated disposal 
unit. This alternate disposition must be noted on the chronology sheet 
that is kept as part of the claims file. Claims personnel will not 
divert such items to personal use or use them to furnish Government 
offices. In determining whether an item has salvage value, the size of 
the item and the distance the claimant must travel to turn it in should 
be considered. A claimant must

[[Page 418]]

make his own arrangements to transport salvageable items prior to 
payment. Claims personnel should ask the claimant's command to make 
transportation available to assist the claimant in appropriate cases, 
particularly when the item is large or bulky. Sound discretion prohibits 
requiring a claimant living far from a designated disposal unit to turn 
in an item of relatively slight value.
    (2) Turn-in to the carrier. On CONUS domestic shipments, the carrier 
may choose to pick up items for which it will fully reimburse the 
Government. Pursuant to a Joint Military-Industry Memorandum on Salvage, 
items that are hazardous to keep around, such as mildewed items or 
broken glass (except items such as figurines and crystal with a per item 
value of more than $50.00), may be disposed of as the claimant chooses. 
Claimants must retain other items for a maximum of 120 days from the 
date of delivery to allow the carrier to pick them up. Pursuant to this 
memorandum of understanding, the carrier has until the end of the 
inspection period or 30 days after receipt of the demand, whichever is 
greater, to identify such items. Claims offices must identify files in 
which the carrier is entitled to salvage and must process these claims 
for recovery action within 30 days so that the claimant does not dispose 
of salvageable items before the end of the period allotted for carrier 
pick-up.
    (3) Maximum allowances. If the claimant will not be fully 
compensated for an item because a maximum allowance is applied, he will 
not be required to turn in the item.
    (e) Standard abbreviations. The claims examiner's intent should be 
clear and unmistakable to anyone reviewing the remarks section of DD 
Form 1844. The following standardized abbreviations are used in 
completing the remarks section. Other abbreviations should not be used. 
Whenever one or more of these abbreviations will not adequately explain 
how the claimant has been compensated, a brief explanation should be 
inserted in the remarks section, in the comments section on the bottom 
of DD Form 1844, or on the chronology sheet that is kept in each claims 
file.
    (1) AC: Amount claimed. The amount claimed was awarded to the 
claimant. This abbreviation is not used if the claimant has presented an 
estimate of repair.
    (2) AGC: Agreed cost of repairs. The claimant did not present an 
estimate but instead, after discussing the matter with claims personnel, 
entered an amount that represents the claimant's guess as to how much it 
would cost to repair the damaged item. The claims office may accept this 
amount as a fair estimation of the cost of repair based on the amount of 
damage, the value of the item, and the cost of similar repairs in the 
area. A claimant may be allowed up to $50.00 as an AGC without an 
inspection and between $50.00 and $100.00 if claims personnel have 
inspected the item. The use of AGC is an integral part of small claims 
procedures.
    (3) CR: Carrier recovery. The claimant was paid this amount by the 
carrier for the item. The payment is recorded in the remarks column, and 
the total carrier payment is deducted at the bottom of DD Form 1844 in 
the same manner as insurance recovery.
    (4) D: Depreciation. Yearly depreciation was taken on the destroyed 
or missing item in accordance with the appropriate depreciation guide in 
effect at the time of the loss. Deviations from standard rates must be 
explained.
    (5) DV: Depreciated value. A claimant's repair costs exceeded the 
value of the item, so the depreciated value was awarded instead. 
Whenever a claimant claims a repair cost that is very high, relative to 
the age and probable replacement cost, the replacement cost should be 
obtained and the depreciated value determined.
    (6) ER: Estimate of repair. The claimant provided an estimate of 
repair that was used to value the loss. If multiple estimates were 
provided, they should be numbered and referred to as exhibits.
    (7) EX: Exhibit. When numerous documents have been provided to 
substantiate a claim, they should be numbered and referred to as 
exhibits.
    (8) FR: Flat rate depreciation. Flat rate depreciation was taken on 
an item in accordance with the Depreciation Guide in effect at the time 
of the loss.

[[Page 419]]

Deviations from the normal rate must be explained.
    (9) F&R: Fair and reasonable. A fair and reasonable award was made 
(see Sec. 751.12(b)(3)).
    (10) LOV: Loss of value. An LOV was awarded (see Sec. 751.5(a)(1)).
    (11) MA: Maximum allowance. The adjudicated value, listed in the 
``Amount Allowed'' column, exceeds a maximum allowance. The amount in 
excess of the maximum allowance is subtracted at the bottom of the DD 
Form 1844.
    (12) N/P: Not payable. The item is not payable. The reason for this 
comment should be noted (i.e., ``not substantiated'').
    (13) OBS: Obsolescence. A percentage was deducted for obsolescence.
    (14) PCR: Lost potential carrier recovery. A deduction was made for 
lost PCR.
    (15) PED: Preexisting damage. A deduction was made for PED.
    (16) PP: Purchase price. The purchase price was used to value the 
loss. Normally, the purchase price is not an adequate measure of the 
claimant's loss. If, however, the claimant used the replacement cost of 
a dissimilar item or otherwise failed to substantiate the replacement 
cost, a recent purchase price may be used at the discretion of claims 
personnel, if a true replacement cost is not available.
    (17) NEX: Navy Exchange replacement cost. A replacement from the NEX 
was used.
    (18) RC: Replacement cost. A replacement cost was used. The store or 
catalog from which the replacement cost was taken should be listed.
    (19) SV/N: Item has no salvage value. A destroyed item was 
determined to have no salvage value.
    (20) SV/R: Salvage value, item retained. A destroyed item was 
determined to have salvage value and the claimant chose to keep the 
item. Accordingly, a deduction was made for the salvage value.
    (21) SV/T: Salvage value, item turned in. A destroyed item was 
determined to have salvage value and the claimant chose not to keep the 
item. If the item is part of a CONUS domestic shipment, the claimant 
must keep it for the carrier to pick up. Otherwise, the claimant must 
turn the item in prior to payment on the claim.
    (f) Sets. Normally, when component parts of a set are missing or 
destroyed, the claimant is only entitled to the replacement cost of the 
missing or destroyed components. In some instances, however, a claimant 
would be entitled to replacement of the entire set or to an additional 
LOV. Some claimants will assert that all of the items in a room are part 
of a set. Pieces sold separately, however, are ordinarily not considered 
parts of a set, and pieces that merely complement other items, such as a 
loveseat purchased to complement a particular hutch, are never 
considered part of a set. When a component part of a set is missing or 
destroyed and cannot be replaced with a matching item, or has to be 
repaired so that it no longer matches other component parts of the set, 
the following rules apply:
    (1) The set is no longer useful for its intended purpose. When a set 
is no longer useful for its intended purpose because component parts are 
missing or destroyed the entire set may be replaced. Note that several 
firms will match discontinued sets of china and crystal and that 
replacement of the set is not authorized if replacement items can be 
thus obtained. Generally, with china and crystal the value of the set as 
a whole is not destroyed unless more than 25 percent of the place 
settings are unusable. Exceptions may be made if the claimant can 
demonstrate a particular need for a certain number of place settings 
because of family size or social obligations. In those rare instances 
when an entire set is replaced, the claimant will be required to turn in 
undamaged pieces.
    (2) The set is still useful for its intended purpose. When missing 
pieces cannot be matched and there is measurable decrease in the value 
of the set, but the set is still useful for its intended purpose, the 
claimant is awarded the value of the missing pieces plus an amount for 
the diminution in value of the set as a whole. The amount awarded as an 
LOV will vary depending on the exact circumstances.
    (3) Mattresses and upholstered furniture are recovered. A mattress 
and box spring set is covered during normal

[[Page 420]]

use. Such sets are still useful for their intended purpose if one piece 
of the set has to be recovered in a different fabric. No award will be 
made for the undamaged piece. When one piece of a set of upholstered 
furniture suffers damage that cannot be repaired or recovered in 
matching fabric, recovering the entire set or recovering the damaged 
piece plus LOV should be considered. Factors to take into account 
include the value of the set, PED to the set, the nature of the current 
damage, and the extent to which the claimant's furniture is already 
mismatched.
    (g) Mobile homes. Mobile homes present special problems. Most mobile 
homes, particularly larger ones, are not built to withstand the stress 
of multiple long moves. While the Mobile Home One-Time Only rate 
solicitation program, effective 1 November 1987, may have reduced the 
incidence of loss and damage by encouraging carriers to use extra axles 
when necessary, mobile home shipments can result in enormous, 
uncompensated losses for servicemembers and present unusual difficulties 
for claims adjudicators. Because the risk is so great, claims offices 
must coordinate with their servicing transportation offices to ensure 
both that servicemembers shipping mobile homes are advised of the risk 
and of their responsibilities, and that the transportation office does 
not authorize shipment of a mobile home that has not been placed in a 
fit condition to be shipped.
    (1) Transportation counseling prior to shipment. Servicemembers 
should be advised of the following:
    (i) They are responsible for placing the mobile home and its tires, 
tubes, frames, and other parts in fit condition to ship and for loading 
the mobile home to withstand the stresses of normal transportation. They 
will not be compensated for any damage that results either from a latent 
defect in the construction of the mobile home (except when the carrier 
is aware of the defect and the servicemember is not) or from their 
failure to place the mobile home in fit condition to ship.
    (ii) They are responsible for paying for necessary repairs en route. 
Such repairs can amount to several hundred or even several thousand 
dollars, and some mobile homes have been left in storage at the 
servicemember's expense hundreds of miles from destination because the 
owner could not pay for necessary repairs.
    (iii) They are responsible for resealing the roof and 
weatherproofing the mobile home after delivery. The cost of this is not 
compensable, nor is any damage caused by the servicemember's failure to 
have it done.
    (iv) They are responsible for removing obstructions, grading the 
roadway, or otherwise preparing the site to make it accessible for the 
carrier's equipment at both origin and destination.
    (v) Because of the risk that damage will result for which they 
cannot be compensated, servicemembers should strongly consider 
purchasing private insurance coverage. A claimant usually must purchase 
separate insurance for property shipped inside the mobile home and most 
mobile home carriers will sell some sort of insurance coverage for 
damage to the mobile home itself. Often, when a mobile home has been 
moved repeatedly, the risk of uncompensated loss is so high that the 
servicemember should consider selling the home rather than attempting to 
ship it.
    (2) Inspection Prior to Shipment. Transportation personnel should 
inspect the home prior to shipment in all instances. All defects should 
be recorded. In particular:
    (i) A mobile home should not be shipped with a servicemember's 
furniture and other household goods inside. The maximum safe weight of 
appliances and additional property is very low. An overweight mobile 
home tends to blow tires and break apart during shipment. Servicemembers 
should be advised long before shipment that they will have to make other 
arrangements for shipping such items at their own expense.
    (ii) A mobile home should never be shipped with defects in the steel 
frame or tow hitch.
    (iii) The condition of all tires should be checked and recorded. 
Some carriers submit huge bills for ``blown'' tires during shipment.
    (iv) Structural changes to the interior of the home, particularly 
those

[[Page 421]]

that involve cutting through beams, should be examined closely and a 
civil engineer should be called in to render an opinion. Frequently, it 
is not safe to ship mobile homes in which the claimant has altered the 
interior framing.
    (3) Latent Defects. Many carriers will attempt to escape liability 
by attributing all damage to latent manufacturing defects. A loss due to 
such a defect, like a loss due to any other mechanical defect, is not 
considered incident to service. When an engineer's report or other 
evidence shows that damage was indeed caused by a defect rather than by 
the carrier's failure to take the necessary care, the following rules 
apply:
    (i) If both the carrier and the claimant knew or should have known 
of the defect, and if the claimant took no corrective action and had the 
mobile home shipped anyway, the claim is not payable.
    (ii) If the carrier knew or should have known of the defect, and the 
claimant could not reasonably have been expected to know of it, the 
claim is payable and liability should be pursued against the carrier.
    (iii) If neither the claimant nor the carrier could reasonably be 
expected to know of the defect, the claim is not payable.
    (4) Substantiation of a claim. Prior to adjudication of such claims, 
the mobile home should be inspected and the following evidence obtained, 
if possible:
    (i) DD Form 1800 (Mobile Home Shipment Inspection at Destination). 
This document shows the condition of the home at origin prior to 
shipment. This document is prepared by the Transportation Office (TO) 
and is signed by the servicemember, the carrier's representative, and 
the Government inspector. It is vital and a claim should not be paid 
without it. At destination, damages noted at delivery should be 
annotated and the form dated and signed by the driver and the 
servicemember. Damages may be listed on this form or on the DD Form 1840 
(Joint Statement of Loss or Damage at Delivery).
    (ii) DD Form 1863 (Accessorial Services-Mobile Home). For shipments 
after 1 November 1987, DD Form 1863 lists all services the carrier is 
required to provide, including line-haul, payment of tolls, 
overdimension charges, permits and licenses, provision of anti-sway 
devices, axles with wheels and tires, temporary lights, and escort 
services. All costs and services may not appear on the GBL. For 
shipments prior to 1 November 1987, damages may also be listed on this 
form.
    (iii) DD Form 1840/1840R. Beginning 1 November 1987, later-
discovered damages must be listed on DD Form 1840R and dispatched to the 
carrier within 75 days of delivery. Timely notice on mobile home 
shipments differs slightly from such notice on other shipments. Item 306 
of the carrier's rate solicitation provides that ``upon delivery by the 
carrier, all loss of or damage to the mobile home shall be noted on the 
delivery document, the inventory form, the DD Form 1800, and/or the DD 
Form 1840. Late discovered loss or damage, including personal property 
within the mobile home, will be noted on the DD Form 1840R not later 
than 75 days following delivery and shall be accepted by the carrier as 
overcoming the presumption of correctness of delivery receipt.''
    (iv) DD Form 1412 (Inventory of Items Shipped in Housetrailer). 
Prior to 1 November 1987, the servicemember prepared DD Form 1412. After 
1 November 1987, the carrier is required to prepare this in coordination 
with the servicemember.
    (v) DD Form 1841. If a Government representative does not inspect 
the mobile home at delivery, an inspection should be requested.
    (vi) Driver's statement. The mobile home carrier should be requested 
to provide (within 14 days) a statement from the driver of the towing 
vehicle explaining the circumstances surrounding the damage as well as 
detailed travel particulars. If the mobile home carrier does not 
respond, the file should be so annotated. Such statements are often 
self-serving and should be reviewed critically to determine whether the 
carrier is attributing damage to a latent defect.
    (vii) Owner's statement. The claimant should provide a statement 
concerning the age of the mobile home, the date and place purchased, any 
prior damage or repairs, all prior moves, and prior claims.

[[Page 422]]

    (viii) Estimates of repair. When possible, the claimant should 
obtain two estimates of repair from firms in the business of repairing, 
rather than selling, mobile homes. Such estimates should list the 
approximate value of the home before and after damage, a detailed 
breakdown of the repairs needed and their cost, and the cause of damage.
    (ix) Engineer's statement. Where the facts indicate the possibility 
of a latent defect, the claimant should be assisted in obtaining a 
statement from a qualified engineer or vehicle maintenance professional 
with expertise in mobile homes explaining the cause of damage. The 
claims office should coordinate in advance with facilities engineers or 
with local reserve units with engineering expertise to provide such 
inspection where possible.
    (5) Compensable damage. In adjudicating the claim, the claimant may 
be paid for loss of or damage to the mobile home except when the damage 
is due to a latent defect, to the servicemember's failure to place the 
home in fit condition to ship, or to the servicemember's failure to have 
the roof resealed. The servicemember may also be compensated for the 
reasonable cost of repair estimates provided by firms in the business of 
mobile home repair and of opinions prepared by qualified engineers. The 
claimant may not be compensated for services the carrier failed to 
perform or performed improperly or for other incidental expenses. The 
claimant should be referred to the transportation office for these. Such 
services (listed on DD Form 1843 and the GBL correction notice) include:
    (i) Escort or pilot services, ferry fees, tolls, permits, 
overdimension charges, or taxes.
    (ii) Storage costs or parking fees en route.
    (iii) Expand charges and charges for anti-sway devices, brakes and 
brake repairs, or adding or replacing axles, tubes, or tires.
    (iv) Wrecker service.
    (v)Connecting or disconnecting utilities.
    (vi) Blocking, unblocking, or removing or installing skirting.
    (vii) The cost of separating or reassembling and resealing a double-
wide mobile home.
    (6) Carrier liability and attempted waivers. In the absence of 
additional coverage, the carrier's maximum liability for personal 
property shipped with the mobile home is $250.00. The carrier is fully 
liable for damages to the mobile home itself. Carriers are also liable 
for damage caused by third parties with whom they contract, such as 
wrecker services. Some carriers may still try to obtain waivers, from 
the servicemember. A waiver signed by the servicemember, however, is not 
binding on the United States. The Navy is the contracting party and the 
owner has not authority to sign a waiver agreement or any other document 
purporting to exempt the carrier from the liability imposed under the 
GBL.



Sec. 751.13  Payments and collections.

    Payment of approved personnel claims and deposit of checks received 
from carriers, contractors, insurers, or members will be made by the 
Navy or Marine Corps disbursing officer serving the adjudicating 
authority. Payments will be charged to funds made available to the 
adjudicating authority for this purpose. Credit for collections will be 
to the accounting data specified in Navy Comptroller Manual section 
046370, paragraph 2 or in superseding messages, if applicable.



Sec. 751.14  Partial payments.

    (a) Partial payments when hardship exists. When claimants need funds 
to feed, clothe, or house themselves and/or their families as a result 
of sustaining a compensable loss, the adjudicating authority may 
authorize a partial payment of an appropriate amount, normally one-half 
of the estimated total payment. When a partial payment is made, a copy 
of the payment voucher and all other information related to the partial 
payment shall be placed in the claim file. Action shall be taken to 
ensure the amount of the partial payment is deducted from the 
adjudicated value of the claim when final payment is made.
    (b) Marine hardship payments. The Marine claimant's Transportation 
Management Office (TMO) shall ensure

[[Page 423]]

compliance with all requirements of Sec. 751.14(a), and may request 
authority for payment by message from the Commandant of the Marine Corps 
(MHP-40).
    (c) Effect of partial payment. Partial payments are to be subtracted 
from the adjudicated value of the claim before payment of the balance 
due. Overpayments are to be promptly recouped.



Sec. 751.15  Reconsideration and appeal.

    (a) General. When a claim is denied either in whole or in part, the 
claimant shall be given written notification of a the initial 
adjudication and of the right to submit a written request for 
reconsideration to the original adjudicating authority within 6 months 
from the date the claimant receives notice of the initial adjudication 
of the claim. If a claimant requests reconsideration and if it is 
determined that the original action was erroneous or incorrect, it shall 
be modified and, when appropriate, a supplemental payment shall be 
approved. If full additional payment is not granted, the file shall be 
forwarded for reconsideration to the next higher adjudicating authority. 
The next higher adjudicating authority may be the commanding officer of 
the Naval Legal Service Office if a properly delegated subordinate has 
acted initially on the claim. For claims originally adjudicated by the 
commanding offer, the files will be forwarded to the Judge Advocate 
General for final action. The claimant shall be notified of this action 
either by letter or by copy of the letter forwarding the file to higher 
adjudicating authority. The forwarding letter shall include a synopsis 
of action taken on the file and reasons for the action or denial, as 
well as a recommendation of further action or denial.
    (b) Files forwarded to JAG. For files forwarded to JAG in accordance 
with Sec. 751.15(a), the forwarding endorsement shall include the 
specific reasons why the requested relief was not granted and shall 
address the specific points or complaints raised by the clamant's 
request for reconsideration.
    (c) Appeals procedure for claims submitted by Marine Corps 
personnel. Where any of the Marine Corps adjudication authorities listed 
in Sec. 751.8(b) fail to grant the relief requested, or otherwise 
resolve the claim the satisfaction of the claimant, the request for 
reconsideration shall be forwarded together with the entire original 
file and the adjudicating authority's recommendation, to the Judge 
Advocate General.



Secs. 751.16-751.20  [Reserved]



          Subpart B--Demand On Carrier, Contractor, or Insurer



Sec. 751.21  Scope of subpart B.

    Subpart B addresses the recovery process for loss or damage 
occurring during the storage or transport of household goods and other 
personal property for which military personnel and civilian employees 
were paid under the provisions of 31 U.S.C. 3721. The authority for 
pursuing recovery action is found at 31 U.S.C. 3711.



Sec. 751.22  Carrier recovery: In general.

    (a) Responsibility. Recovery of amounts due for personal property 
lost or damaged while in transit or in storage at Government expense is 
a joint Personal Property Office/Naval Legal Service Office 
responsibility. In order to establish liability and to effectively 
pursue a recovery claim against a carrier, warehouseman, or other third 
party, it is essential that all required action be accomplished in an 
expeditious manner. Failure of the property owner or any Government 
agent to exercise diligence in the performance of duties may render 
collection of the claim impossible and thereby deprive the Government of 
rightful revenue. Claims approving and settlement authorities will 
ensure that all actions required of the property owner and naval 
personnel are accomplished promptly.
    (b) Elements of collection. There are four elements in the 
successful assertion and collection of a recovery claim. They are:
    (1) Proving that a transit loss occurred;
    (2) Determining who had responsibility for the goods at the time of 
the transit loss;
    (3) Calculating the amount of damages; and

[[Page 424]]

    (4) Pursuing the responsible party or parties vigorously.



Sec. 751.23  Responsibilities.

    (a) Notice of loss. Claims office personnel must ensure that Notice 
of Loss or Damage, DD Form 1840R, is properly completed and dispatched 
to the liable third party or parties within 75 days of delivery of the 
property.
    (b) Counseling of claimant. Claims office personnel should 
coordinate with the local personal property office to ensure proper 
counseling regarding potential claim procedures.
    (c) Documents. Claims office personnel must obtain from the claimant 
or from the transportation office the following documents needed to 
process recovery actions:
    (1) A copy of the GBL or other document used for shipment or 
storage.
    (2) A copy of the inventory.
    (3) A copy of the DD Form 1840 and DD Form 1840R.
    (4) Where storage in transit was extended from 180 days to 270 days, 
a copy of the authorization from the transportation office allowing this 
extension at Government expense.
    (5) Where storage converted from Government paid storage to storage 
at owner's expense, a copy of the claimant's contract with the 
warehouse.
    (6) When necessary, a copy of DD Form 1164, Service Order for 
Personal Property, from the transportation office.
    (7) When necessary, DD Form 619-1, Statement of Accessorial Services 
Performed, from the transportation office.
    (d) Carrier inspection. Claims office personnel should inform 
claimants that the carrier has the right to inspect damaged goods within 
75 days of delivery, or 45 days of dispatch of DD Form 1840R, whichever 
is later, and that damaged items must be held out for carrier inspection 
during that period. Essential items such as washer, dryer, television 
etc., may be repaired prior to that time if necessary.
    (e) Repair estimates. Claims personnel must ensure that repair 
estimates describe the specific location and damage claimed and that the 
same damage is claimed on DD Form 1844, Schedule of Property and Claims 
Analysis Chart. Repair estimates that merely note ``refinished'' or 
``repaired'' are not acceptable.
    (f) DD Form 1844. Claims personnel must ensure that DD Form 1844 is 
properly completed with the nature and extent of the loss or damage to 
each item fully described, the correct inventory numbers supplied, and 
correct item weights utilized from the Military-Industry Table of 
Weights (when these weights are required for the code of service 
involved).
    (g) Demands on third parties. Claims personnel must ensure that 
written demands against appropriate third parties are prepared as 
described in Sec. 751.26 and Sec. 751.27. No demand will be made where 
it conclusively appears that the loss or damage was caused solely by 
Government employees or where a demand would otherwise be clearly 
improper under the circumstances. If it is determined that a demand is 
not required, a brief written statement setting forth the basis for this 
determination will be included on the chronology sheet. Pursuant to the 
Joint Military-Industry Agreement on Claims of $25.00 or Less, claims of 
$25.00 or less will not be pursued because administrative costs outweigh 
recovery proceeds.



Sec. 751.24  Notice of loss or damage.

    (a) Exceptions. The claimant is required to take exceptions and note 
any loss of damage at the time of delivery on the DD Form 1840 (Joint 
Statement of Loss or Damage at Delivery). Later discovered damage must 
be noted on the DD Form 1840R (Notice of Loss or Damage) and delivered 
to the claims office or Personal Property Office within 70 days of 
delivery. Failure to take exceptions at delivery and note and report 
later discovered damage will result in deduction on any lost potential 
carrier recovery from payment of the claim. Failure to note on the DD 
Form 1840 items missing at the time of delivery may result in denial of 
claims for those items.
    (b) DD Form 1840/1840R. The DD Form 1840/1840R is printed in carbon 
sets of five with DD Form 1840 on the front side and DD Form 1840R on 
the reverse side. DD Form 1840/1840R is provided by the carrier to the 
member at delivery. Carriers were required to use this revised DD Form 
1840/1840R beginning 15

[[Page 425]]

August 1988 for international shipments and 15 September 1988 for 
domestic shipments. This is the only document the carriers will accept 
for reporting loss and damage to household goods. The requirement to 
list all know loss and damage at the time of delivery on the DD Form 
1840 is a joint responsibility of the claimant and the carrier. If the 
carrier fails to give the claimant a DD Form 1840 at the time of the 
delivery, the carrier is liable for all damage and does not have to be 
notified in the 75-day timeframe
    (c) Military-Industry Memorandum of Understanding on Loss and Damage 
Rules. The Military-Industry Memorandum of Understanding on Loss and 
Damage Rules became effective in 1985 with the implementation of the new 
DD Form 1840/1840R. This document should be thoroughly studied and 
completely understood.



Sec. 751.25  Types of shipments and liability involved.

    (a) Codes 1 and 2 (domestic including Alaska). Increased released 
valuation, also referred to as ``Basic Coverage,'' became effective 
within CONUS and Alaska on 1 April 1987 for intrastate shipments 
(shipments within a single State), and on 1 May 1987 for interstate 
shipments (shipments from one State to another). For Codes 1 and 2 
shipments picked up after these dates, the carrier's released valuation 
(the carrier's maximum liability for loss and damage) increased from 
$.60 per pound per article to $1.25 multiplied by the net weight of the 
shipment ($2.50 for shipments to and from Alaska). For Codes 1 and 2 
shipments picked up prior to these dates, carrier liability remains at 
$.60 per pound per article and is calculated the same as for Code 4 
shipments. There are also two higher levels of coverage available in 
which the owner pays the difference between the basic coverage and the 
higher level requested: High or higher increased released valuation 
(Option 1) and full replacement protection (Option 2). These higher 
carrier released valuation rates only apply to Codes 1 and 2 shipments 
and they do not affect the liability of a non-temporary storage (NTS) 
warehouse which remains at $50.00 per line item.
    (1) Increased Released Valuation (IRV). IRV is the basic valuation 
for service Codes 1 and 2 and is fully paid by the Government. If the 
claimant is due additional recovery money, the words ``claimant due 
carrier recovery'' must be added on the claims file to ensure the 
recovered amount is provided to the claimant if eligible. IRV is not 
reflected on the GBL by an special language. For Codes 1 and 2 shipments 
picked up after the effective dates mentioned above, the carrier's 
released valuation is $1.25 multiplied by the new weight of the shipment 
($2.50 multiplied times the net weight of the shipment for shipments to 
and from Alaska). For example, if the weight of an IRV shipment moved 
from Kansas to New York is 10,000 pounds, the most the carrier could be 
held liable for would be $12,500 (10,000 pounds times $1.25=$12,500). If 
the same shipment was moved from Alaska to New York, the maximum carrier 
liability would instead be $25,000 (10,000 pounds times $2.50=$25,000).
    (2) Higher Increased Released Valuation (Option 1). This type of 
coverage may be purchased by an owner who desires protection for items 
whose value exceeds a maximum allowance or for a shipment whose value 
exceeds the statutory maximum. If the claimant is due additional 
recovery money, the words ``claimant due carrier recovery'' must be 
added in the claims file. Option 1 must be annotated on the original 
GBL. A GBL correction notice is acceptable only if the carrier or his 
agent has notice of the correction before pick-up. Option 1 may be 
listed in block 27 or block 30 either as a lump sum, such as ``Option 1-
-$30,000,'' or as a multiple, such as ``Option 1--$3.00 times the net 
weight.'' The carrier's maximum liability is whatever higher valuation 
the claimant places on the shipment. For example: The owner of a 10,000 
pound shipment requests Option 1 coverage of $30,000.00 and has this 
listed on the GBL. The carrier's maximum liability is $30,000.00. Under 
basic coverage, the carrier's maximum liability for this shipment would 
only be $12,500.00. The claimant must initially file a claim with the 
carrier. The Government will only accept a claim if the carrier denies 
the claim, if delay would

[[Page 426]]

cause hardship, or if the carrier fails to satisfactorily settle the 
claim within 30 days. The claim is adjudicated in the normal fashion, 
applying depreciation and maximum allowances. Demand is then made on the 
carrier for the full value of the item lost or damaged. When recovery is 
effected, the Government keeps an amount equal to that paid to the 
claimant and disperses the remaining recovery to the claimant.
    (3) Full Replacement Protection (Option 2). This type of coverage 
may be purchased by an owner who desires protection for items whose 
value exceeds a maximum allowance, for a shipment whose value exceeds 
the statutory maximum, or because the claimant does not wish to have the 
replacement cost of destroyed or missing items depreciated to their fair 
market value. The minimum coverage available under Full Replacement 
Protection is $21,000.00 or $3.50 times the net weight of the shipment, 
whichever is greater. A member who chooses this coverage must initially 
file a claim with the carrier, allowing the carrier the right to repair 
or replace items. The Government will only accept a claim if the carrier 
denies the claim, if delay would cause hardship, or if the carrier fails 
to satisfactorily settle the claim within 30 days. If a claim is 
submitted to the Government, the claim is adjudicated normally, applying 
depreciation and maximum allowances. The claimant should be informed 
that any additional amount will be forwarded after recovery action is 
effected against the carrier. Option 2 must be annotated on the original 
GBL. A GBL correction notice is acceptable only if the carrier or his 
agent receives notice of the correction before pick-up. Option 2 may be 
listed in block 27 or block 30 either as a lump sum, such as ``Full 
Replacement Protection--$50,000.00,'' or as a multiple, such as ``Full 
Replacement Protection--$3.50 times the net weight.'' The carrier's 
maximum liability is the higher valuation the claimant places on the 
shipment. For example: The owner of a 10,000 pound shipment requests 
full replacement protection of $3.50 times the net weight of the 
shipment and has this listed on the GBL. The carrier's maximum liability 
is $35,000.00 (10,000 pounds times $3.50=$35,000.00). Under basic 
coverage, the carrier's maximum liability for this shipment would only 
be $12,500.00.
    (4) Calculating liability on IRV, Option 1, and Option 2 shipments. 
(i) Under IRV and Option 1, the carrier's maximum liability for loss or 
damage to a single item is limited to the repair cost or depreciated 
replacement cost of the item. Under Option 2, the carrier's maximum 
liability for a single item is the repair cost or the undepreciated 
replacement cost of the item. The carrier's maximum liability for the 
entire claim is limited to the released valuation, which is either the 
lump sum declared by the owner or the net weight of the shipment times 
the applicable multiplier. The net weight of the shipment is normally 
listed in block 4 of DD Form 1840 (block 3 of DD Form 1840 dated 
September 84). If the net weight is missing, it should be obtained from 
the transportation office.
    (ii) In completing the carrier liability section of DD Form 1844, 
ignore the Joint Military-Industry Table of Weights. Assert the amount 
adjudicated on each item for which the carrier is liable in the carrier 
liability column. Where the Government payment was limited by 
application of a maximum allowance (or by depreciation on full 
replacement cost claims), assert the full, substantiated value. Total 
the amounts for which the carrier is liable in the carrier liability 
column. If this total exceeds the maximum carrier liability for the 
entire claim, the maximum carrier liability should be entered on DD Form 
1843 as the amount demanded. Do not, however, change the total of the 
amounts for which the carrier is liable on the DD Form 1844.
    (iii) If the amount the claimant receives from the Government is 
limited by application of a maximum allowance (or by depreciation on 
full replacement protection claims) leaving the claimant with an 
uncompensated loss, the claimant may be due reimbursement from recovery 
money after recovery is effected on the claim. Claimants with 
uncompensated losses who have basic coverage are only entitled to 
reimbursement from recovery money if the amount recovered exceeds the 
amount paid by the Government (unless the loss was in excess of the

[[Page 427]]

statutory maximum). Claimants with uncompensated losses who purchased 
Option 1 or Option 2 are entitled to reimbursement up to the value of 
their additional coverage. Such files should be marked: ``claimant due 
carrier recovery.'' The claimant should be informed that recovery from 
the carrier is dependent on the amount and quality of the substantiation 
the claimant provided, and that the actual recovery may be less than 
anticipated. The claimant should further be informed that considerable 
time will elapse before recovery is effected and reimbursement made. 
Such claims should be processed for recovery action as expeditiously as 
possible.
    (b) Codes 4 and 6 (International and Hawaii). On Codes 4 and 6, 
international GBL shipments, carrier liability is computed at $.60 per 
pound multiplied by the weight of the article or carton as prescribed by 
the Joint Military-Industry Table of Weights. In cases where the entire 
shipment is lost or damaged, liability will be computed on the net 
weight of the shipment times $.60 per pound. The net weight of the 
shipment may be obtained from the origin transportation office.
    (c) Codes 5 and T (International and Hawaii). (1) A Code 5 shipment 
is the movement of household goods in Military Traffic Management 
Command (MTMC) approved door-to-door shipping containers (wooden boxes) 
and where a carrier provides line-haul service from origin residence to 
a military ocean terminal. The Government, through the Military Sealift 
Command (MSC), provides ocean transportation to the designated port of 
discharge, and the carrier provides line-haul service to the destination 
residence.
    (2) A Code T shipment is the movement of household goods where the 
carrier provides containerization at origin and transportation to the 
designated Military Airlift Command (MAC) terminal. MAC provides 
terminal services at both origin and destination, and air transportation 
to a designated MAC terminal. The carrier provides transportation to the 
destination residence.
    (3) On Code 5 and T shipments, it is often difficult to decide 
whether the Government or the carrier was in actual custody of the 
shipment at the time of loss or damage. In order to reduce liability 
disputes in such situations, a 50-percent compromise agreement between 
industry and the military has been reached.
    (4) When the 50-percent compromise is appropriate or applicable, the 
DD Form 1844 is prepared in the normal fashion utilizing weights 
indicated in the Military-Industry Table of Weights multiplied by $.60 
per pound. Two different sums should be listed for carrier liability at 
the bottom of the DD Form 1844, the amount of liability due under the 
50-percent compromise and the full amount that will be offset if carrier 
fails to pay, e.g., ``$100.00 Code T, $200.00 Full Liability.'' This 
same computation should be reflected in the ``amount of claim'' box on 
DD Form 1843 (Demand on Carrier/Contractor). If a carrier refuses to 
make a satisfactory settlement or fails to make a timely response to the 
demand, the carrier's full liability will be collected.
    (d) Codes 7, 8, and J (Unaccompanied Baggage Shipments). Gross 
Weight Rules. Government payment to the carrier for transportation of 
unaccompanied baggage (Codes 7, 8, and J) is based upon gross weight of 
the shipment. Unless the inventory is prepared as a ``Proper Household 
Goods Descriptive Inventory,'' computation of carrier liability for loss 
or damage incurred in a Code 7, 8, or J shipment will also be based upon 
gross weight. Gross weight is defined as the total weight of all 
articles, including necessary packing materials and packing containers. 
The shipping container is the external crate (tri-wall or other 
Government approved container) into which individual articles and/or 
packing cartons are placed. For the majority of claims, liability will 
be asserted on gross weight of the container.
    (2) Baggage shipments prepared using a ``Proper Household Goods 
Descriptive Inventory.'' The Joint Military/Industry Table of Weights 
will apply to Code 7, 8, or J unaccompanied baggage shipments if the 
inventory has been prepared as a ``Proper Household Goods Descriptive 
Inventory,'' in accordance with Paragraph 54 of the Tender of Service 
for Personal Property Household Goods and Unaccompanied Baggage (DOD 
4500.34-R, appendix A). A

[[Page 428]]

properly prepared inventory should reflect the size of each individual 
carton, give a general description of carton contents, and note 
preexisting damage. The complete inventory, not just a portion, must 
have been prepared as a proper household goods inventory. If an 
inventory is only partially prepared as a proper household goods 
descriptive inventory, gross weight will be used.
    (e) Local moves and NTS. There are basically two types of NTS 
shipments: A direct delivery from NTS by the same company that stored 
the property and a delivery from NTS which was picked up at the 
warehouse by a GBL carrier. Direct deliveries of household goods from 
NTS are often erroneously construed as local moves. It is sometimes 
difficult to tell the difference between the two since a shipment 
delivered from NTS by the warehouseman is usually also a short distance 
(local) move. The type of contract involved determines whether or not 
the shipment is considered a local move, a direct delivery from NTS, or 
a carrier delivery picked up from NTS. These distinctions are important 
since different liability is involved.
    (1) Local move. A local move is a shipment performed under a local 
contract that authorizes property to be moved from one residence to 
another within a specified area (usually a move from off base to on 
base, or the reverse). The contract for a local move is the purchase 
order prepared by the transportation office which lists the services 
required of the carrier in accordance with the provisions of the Federal 
Acquisition Regulation (FAR). The purchase order usually includes 
packing and picking up the goods at origin residence or from storage, 
transporting the goods within a designated distance, and delivering and 
unpacking the goods at destination. All these services are performed 
under the authority of one purchase order and will usually be 
accomplished the same day or within a few days of pickup. Timely notice 
must exist in order to pursue carrier recovery and liability is usually 
based on a released valuation of $.60 per pound per article. The Joint 
Military/Industry Table of Weights is used to calculate liability. There 
is no insurance coverage required on local contractors; if the local 
contractor is no longer in business or bankrupt, the file may be closed.
    (2) Direct delivery from NTS. In circumstances where one contractor 
is responsible for pick-up, NTS, and delivery of the shipment, liability 
for loss or damage is assessed against that carrier. Nontemporary 
storage of household goods requires completion of DD Form 1164 (Service 
Order for Personal Property) in accordance with the provisions of the 
Basic Ordering Agreement (BOA). The ``handling-in'' portion of the 
shipment is accomplished by issuance of the Initial Service Order, DD 
Form 1164. The goods are usually stored for a period of 6 months to 4 
years. The ``handling-out'' and post-storage services are accomplished 
by a supplemental service order. These are usually long term storage, 
short distance moves processed under the authority of at least two 
documents: the initial service order and the supplemental service order. 
The BOA states that the contractor shall be liable ``in an amount not 
exceeding fifty dollars ($50.00) per article or package listed on the 
warehouse receipt or inventory form'' (i.e., $50.00 per inventory line 
item).
    (3) Carrier delivery picked up from NTS. The NTS portion of the 
shipment requires completion of an Initial Service Order, DD Form 1164, 
to accomplish the ``handling-in'' of the goods into the warehouse for 
storage, as prescribed by the provisions of the BOA. When storage is 
terminated, the ``handling-out'' and post-storage services are 
accomplished by issuance of a GBL in accordance with the tender of 
service. The GBL may be issued to a different company or in some cases 
to the same company that stored the goods. These are long-term storage, 
long-distance moves processed under the authority of two documents: the 
initial service order and the GBL. Liability is assessed entirely 
against the delivering carrier at whatever rate is appropriate for the 
code of service involved, unless the carrier prepares an exception sheet 
(rider) noting damage or loss at the time the goods are picked up from 
the warehouse. The exception sheet must be signed by a warehouse 
representative.

[[Page 429]]

If a valid exception sheet exists, liability for items noted on the 
exception sheet is assessed against the NTS warehouse at $50.00 per 
inventory line item. An exception sheet should be prepared by the GBL 
carrier who picks up the goods from NTS even if that carrier is the same 
company that stored the goods. This is necessary in order to relieve the 
carrier from liability as a carrier. If either the carrier alone, or 
both the carrier and the NTS facility, fail to pay their proper 
liability, the file is forwarded to the Naval Material Transportation 
Office, (NAVMTO), Norfolk, Virginia for offset action.
    (f) Direct Procurement Method (DPM). (1) A DPM move is a method in 
which the Government manages the shipment from origin to destination. 
Contracts are issued to commercial firms for packing, containerization, 
local drayage, and storage services, or Government facilities and 
employees provide these services. Separate arrangements are made with 
carriers and separate documents are issued for each segment throughout. 
DPM contractors are also known as packing and crating (P&C) contractors, 
as local drayage contractors, or just as local contractors.
    (2) GBL's for DPM shipments are usually only issued to motor freight 
carriers.
    (i) Block 3 on the GBL entitled ``service code'' will contain the 
letters A, B, H, or V, followed by a second letter A, H, K, N, P, R, W, 
X, or Y. These two letter codes identify the GBL as a DPM contract.
    (ii) Block 18, ``consignee,'' and Block 19, ``from,'' on the GBL 
contain the name and address of another carrier or transportation office 
rather than the name and address of the claimant.
    (iii) Block 27, ``description of shipment,'' on most GBL's contains 
the statement, ``household goods released at a value of 10 cents per 
pound per article.'' This refers to the motor freight carrier's 
liability only. The origin and destination contractors' liability is 
still $.60 per pound times the weight of the article or carton, as 
indicated in the Joint Military/Industry Table of Weights.
    (iv) If liability lies against the motor freight carrier, the term 
``article'' is defined as the weight of each packed item, such as the 
weight of a broken dish within a carton rather than the net weight of a 
carton, as used against the origin and destination contractors. 
Liability is computed against the motor freight carrier at a rate of 
$.10 per pound times the weight of the article.
    (3) Since 1 January 1981 the destination contractor has been held 
liable for loss and damage unless it can prove that it is not at fault, 
i.e., took exceptions prior to receipt of goods. The motor freight 
carrier is liable for any damage or loss noted against it during its 
portion of the move. If the motor freight carrier has noted specific 
damage when it received the shipment, liability is charged against the 
origin contractor at $.60 per pound times the weight of the article or 
carton. Damage noted against the origin contractor or motor freight 
carrier should be indicated on a valid shipping document and generally 
involves distinct damage to or missing containers. These documents must 
be signed by all parties involved in the transfer of the goods.
    (4) The destination contractor must receive timely notice of loss or 
damage via DD Form 1840/1840R and a demand packet. If exceptions were 
taken against the origin contractor or motor freight carrier on a 
transfer document, they should receive only demand packets.
    (5) In determining destination or origin contractor's liability, the 
term ``article'' has been defined as each shipping carton or container 
and the contents thereof, less any exterior crate or shipping carton. 
The net weight of each article (carton or box) packed within the 
exterior crate or carton may be used to determine the contractor's 
liability for a damaged or missing item originating out of that carton.
    (6) Claims offices should obtain a copy of the DPM contract from the 
local contracting office or transportation office in order to identify 
which company has the DPM contract and verify the limits of the 
liability clause. Contracts are awarded on a calendar-year basis.
    (g) Mobile homes. Mobile home claims represent such a small 
percentage of claims received that claims personnel

[[Page 430]]

are often unfamiliar with the requirements and documentation necessary 
to process such claims. For an explanation of the adjudication of such 
claims and the forms used to effect shipment, see Sec. 751.12(g) above.
    (1) Carrier liability--(i) For damage to the mobile home. Carrier 
liability for damage to a mobile home is generally the full cost of 
repairs for damage incurred during transit. A mobile home carrier is 
excused from liability when the carrier can introduce substantial proof 
that a latent structural defect (one not detectable during the carrier's 
preliminary inspection) caused the loss or damage.
    (ii) For damage to contents. The carrier's liability for loss or 
damage to household or personal effects inside the mobile home (such as 
clothing and furniture. or furnishings which were not part of the mobile 
home at the time it was manufactured) is limited to $250.00 unless a 
greater value is declared in writing on the GBL. Under the Mobile Home 
One-Time-Only (MOTO) rate system, effective for shipments after 1 
November 1987 the owner no longer prepares his own inventory. Under the 
MOTO system, the carrier in coordination with the owner is required to 
prepare a legible descriptive inventory on DD Form 1412, Inventory of 
Articles Shipped in House Trailer.
    (iii) Agents of the mobile home carrier. If the shipment is 
transferred to another mobile home carrier for transport, the first 
carrier will continue to be shown on the GBL and is responsible for the 
mobile home from pickup to delivery. The carrier is also responsible for 
damage caused by third parties it engages to perform services such as 
auxiliary towing and wrecking.
    (iv) Water damage. Water damage to a double-wide or expando-type 
mobile home is usually due to the carrier's failure to provide 
sufficient protection against an unexpected rainstorm. Carriers will 
often assert that this damage is due to an ``act of God'' and attempt to 
avoid liability. It is, however, the carrier's responsibility to ensure 
safe transit of the mobile home from origin to destination. Not only 
should carriers be aware of the risk of flash floods and storms in 
certain locales during certain seasons, but a carrier is supposed to 
provide protective covering over areas of the mobile home exposed to the 
elements. Carrier recovery should be pursued for water damage to these 
types of mobile homes.
    (v) Waivers signed by the claimant. The carrier may attempt to 
escape liability by having the owner execute a waiver of liability. Such 
waivers are not binding upon the United States.
    (vi) Extensions of storage in transit (SIT). The extension of SIT 
past 180 days is only applicable to household goods and holdbaggage 
shipments. It is not applicable to the shipment of mobile homes. If a 
mobile home remains in SIT past 180 days, storage is at the owner's 
expense.
    (2) Notice. Item 306 of the carrier's rate solicitation states that: 
``Upon delivery by the carrier, all loss of or damage to the mobile home 
shall be noted on the delivery document, the inventory form, the DD Form 
1800, and/or the DD Form 1840. Late(r) discovered loss or damage, 
including personal property within the mobile home, will be noted on DD 
Form 1840R not later than 75 days following delivery and shall be 
accepted by the carrier as overcoming the presumption of correctness of 
delivery receipt.'' Notification to the carrier may be made on any of 
the documents. Claims personnel will dispatch the DD Form 1840R in 
accordance with Sec. 751.14.
    (3) Preparation of demands. The carrier is liable for the full 
amount of substantiated damage to the mobile home itself (less estimate 
fees), plus up to $250.00 for loss or damage to contents (unless the 
claimant purchased increased released valuation on the contents). 
Prepare a demand for this amount. In addition to the DD Form 1843 and DD 
Form 1844, the demand packet should include the following documents:
    (i) DD Form 1800, Mobile Home Inspection Record;
    (ii) DD Form 1863, Assessorial Services, Mobile Home;
    (iii) DD Form 1840/1840R, Joint Statement of Loss or Damage at 
Delivery/Notice of Loss;
    (iv) DD Form 1412, Inventory of Items Shipped in House Trailer;
    (v) DD Form 1841, Government Inspection Report;

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    (vi) Driver's statement, from the driver of the towing vehicle;
    (vii) Claimant's statement concerning previous moves;
    (viii) Estimates of repair, preferably two, from firms in the 
business of repairing mobile homes; and
    (ix) Engineer's statement, or statement by other qualified 
professionals.
    (4) References. Chapter 3 and Appendix E of DOD 4500.34-R, pertain 
to mobile home shipment and contain much valuable information. Another 
source is NAVSUP 490, Chapter 10 ``Mobile Homes of Military Personnel.''



Sec. 751.26  Demand on carrier, contractor, or insurer.

    (a) Carrier. When property is lost, damaged, or destroyed during 
shipment under a GBL pursuant to authorized travel orders, the claims 
investigating officer or adjudicating authority (whichever can more 
efficiently perform the task) shall file a written claim for 
reimbursement with the carrier according to the terms of the bill of 
lading or contract. This demand shall be made against the last carrier 
known to have handled the goods, unless the carrier in possession of the 
goods when the damage or loss occurred is known. In this event, the 
demand shall be made against the responsible carrier. If it is apparent 
the damage or loss is attributable to packing, storing or handling while 
in the custody of the Government, no demand shall be made against the 
carrier.
    (b) Marine Corps claimants. For Marine Corps claimants, the claims 
investigating officer will prepare the claim against the carrier, 
contractor, and/or insurer and will mail it (together with the DD Form 
1842 claim package) to the Commandant of the Marine Corps (MHP-40), who 
will submit and assume the responsibility of monitoring the claim 
against the carrier.
    (c) NTS warehousemen. Whenever property is lost, damaged, or 
destroyed while being stored under a basic agreement between the 
Government and the warehouseman, the claims investigating officer, or 
appropriate Naval Legal Service Command (NLSC) activity, shall file a 
written claim for reimbursement with the warehouseman under the terms of 
the storage agreement.
    (d) Insurer. When the property lost, damaged, or destroyed is 
insured, the claimant must make a demand against the insurer for payment 
under the terms of the insurance coverage within the time provided in 
the policy. If the amount claimed is clearly less than the policy 
deductible, no demand need be made. Failure to pursue a claim against 
available insurance will result in reducing the amount paid on the claim 
by the amount which could have been recovered from the insurer. When an 
insurer makes a payment on a claim in which the Government has made a 
recovery against the carrier or contractor, the insurer shall be 
reimbursed a pro rated share of any money recovered.



Sec. 751.27  Preparation and dispatch of demand packets.

    Demand on a carrier or contractor shall be made in writing on DD 
Form 1843 (Demand on Carrier) with a copy of the adjudicated DD Form 
1844 (Schedule of Property) attached.
    (a) Demand packets. A demand is a monetary claim against a carrier, 
contractor, or insurer, to compensate for loss or damage incurred to 
personal property during shipment or storage. DD Form 1843 represents 
the actual demand. The demand packet is a group of documents, stapled 
together and sent to the liable third party. More than one demand packet 
should be prepared when more than one party is deemed to be liable. Do 
not use original documents. Demand packets should be mailed in official 
DON envelopes. No demand packet should be prepared for claim files that 
have been closed or when potential recovery is $25.00 or less. In those 
cases the outside of file folders in the upper left-hand corner should 
be marked ``CLOSED.'' A demand packet will include the following:
    (1) DD Form 1843, Demand on Carrier/Contractor;
    (2) DD Form 1844, Schedule of Property and Claim Analysis Chart;
    (3) DD Form 1841, Government Inspection Report (if available);
    (4) DD Form 1164, Service Order for Personal Property (when 
applicable);

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    (5) Copies of all repair estimates (translated from foreign 
languages); and
    (6) Copies of all other supporting documents deemed appropriate.
    (b) Dispatch of demand packets. (1) The demand packets are directly 
dispatched by the appropriate personal property office or the Naval 
Legal Service Office to the third party.
    (2) Privately Owned Vehicles (POV's). Demands for loss or damage to 
POV's will not be made directly against ocean carriers operating under 
contract with the MSC. After payment is made to the claimant, one copy 
of the complete claim file will be forwarded directly to Commander, MSC. 
Each file shall include the following:
    (i) The payment voucher;
    (ii) The completed personnel claim forms;
    (iii) The estimated or actual cost of repair;
    (iv) A document indicating the conditions of the items upon delivery 
to the carrier; and
    (v) a document indicating the forwarding condition of the POV upon 
its return to Government control.
    The letter of transmittal should identify the vessel by name, 
number, and if available, the sailing date.



Sec. 751.28  Assignment of claimants rights to the government.

    The claimant shall assign to the Government, to the extent of any 
payment made on the claim, all rights and interest the claimant may have 
against any contractor, carrier, or insurer or other party arising out 
of the incident on which the claim is based. The claimant shall also 
furnish such evidence as may be required to enable the Government to 
enforce its claim. If the claimant refuses to cooperate, steps may be 
taken to ensure return of monies paid on the item which the Government 
is trying to collect.



Sec. 751.29  Recoveries from carrier, contractor, or insurer.

    (a) Recoveries. If a claimant receives payment from the Government 
under this instruction and also receives compensation from a carrier, 
contractor, or insurer for the same loss, the Government shall collect 
from the claimant the amount necessary to prevent the claimant from 
being compensated twice for the same loss. If the amount payable on a 
claim is less than the adjudicated value of the claim, excess recoveries 
from carriers, and other third parties shall be paid to the member as 
long as the total amount paid does not exceed the value of the claim as 
adjudicated.
    (b) Recovered property. When lost property is found, the claimant 
may, at his option, accept all or part of the property and return the 
full payment or a pro-rated share of the payment received from the 
Government on the claim for the recovered property. Surrendered property 
shall be disposed of under applicable salvage and disposal procedures.



Sec. 751.30  Settlement procedures and third party responses.

    (a) Settlement procedures. In the interest of expeditious office 
administration, correspondence to carriers and contractors should be 
kept to a minimum. Normally, one rebuttal to a third party's denial of 
liability is sufficient, unless the carrier or contractor raises new 
arguments or provides new information.
    (1) Checks from third parties. Accept checks for the amount demanded 
from carriers and contractors. If a carrier or contractor forwards a 
check for less than the amount demanded, review the carrier's arguments 
for reducing liability to determine if they are acceptable. If the third 
party's basis for reducing liability is acceptable in the light of all 
evidence, deposit the check and dispatch the unearned freight letter, if 
applicable. Mark the front upper left-hand corner of the file as 
``CLOSED.''
    (2) Third party offers of settlement. If a carrier or contractor 
offers to settle the claim, review the carrier's arguments for reducing 
liability to determine if they are acceptable. If the third party's 
basis for reducing liability is acceptable in light of all evidence, 
inform the carrier that the offer is accepted, but that offset action 
will be initiated if a check for that amount is not received within 45 
days. If a check

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in the amount acceptable to the Government is received, deposit it and 
dispatch the unearned freight letter, if applicable. Mark the front 
upper left-hand corner of the file as ``CLOSED.'' If a check in the 
proper amount is not received within 45 days, send the request to 
NAVMTO, Norfolk (or appropriate contract officer) for offset action (see 
Sec. 751.32 of this part).
    (3) Unacceptable third party checks and offers of settlement. If a 
third party's basis for denying liability is not valid, respond to that 
carrier or contractor. Return unacceptable checks. Explain the reasons 
for not accepting the check or offer, and request the amount that is 
justified under the circumstances in the light of all the evidence. If a 
release was included, amend the release to the revised amount and sign, 
date, witness, and return it. Warn the carrier or contractor that the 
claim will be forwarded for offset action if a check for the amount 
justified under the circumstances is not received within 45 days. 
Suspend the file for 45 days and if a check in the proper amount is 
received, deposit it and dispatch the unearned freight letter, if 
applicable. If a check in the proper amount is not received within 45 
days, request NAVMTO, Norfolk (or appropriate contract officer) to take 
offset action.
    (4) Third party denials of liability. Upon receipt, review the 
carrier or contractor's basis for denying liability in the light of all 
the evidence.
    (i) Acceptable third party reasons for denial. Mark the front upper 
left-hand corner of such files as ``CLOSED.''
    (ii) Partially acceptable and unacceptable third party reasons for 
denial. If the carrier or contractor's basis for denying liability is 
acceptable only in part or is completely unacceptable, follow the 
procedures in subparagraph (3) above, requesting the amount that is 
justified under the circumstances in the light of all the evidence. If a 
response is not received within 45 days, or if the third party's reply 
is not responsive, request NAVMTO, Norfolk (or appropriate contract 
officer) take offset action as described above.
    (b) Depreciation. In determining payments to claimants, the 
depreciation rates from the Allowance List--Depreciation Guide are used. 
In determining third party liability, however, a different depreciation 
guide, the Joint Military/Industry Depreciation Guide is used instead. 
In most instances, the depreciation rates are the same in both guides, 
and claims personnel are not required to consult the Joint Military/
Industry Depreciation Guide or alter the depreciation taken on items 
prior to dispatching demands. If, however, a carrier or contractor 
objects to the depreciation rate utilized for certain items, consult the 
Joint Military/Industry Depreciation Guide and use the depreciation rate 
found in that guide if it differs from the rate in the Allowance List-
Depreciation Guide.



Sec. 751.31  Common reasons for denial by carrier or contractor.

    The following are common reasons given for denial of an entire 
claim, or for individual items on a claim. Each reason for denial is 
followed by a short discussion of the validity of such a denial.
    (a) The carrier alleges that valid exceptions were made at the time 
of pickup from the NTS facility. When a carrier provides an exception 
sheet it contends was made at time of transfer, this exception sheet 
must bear the signature of a representative of the NTS facility. Without 
a signed exception sheet there is no evidence that the NTS facility was 
made aware of these exceptions and given the opportunity to confirm or 
deny the alleged condition of the items in question. The burden of proof 
is on the carrier to provide the valid exception sheet and establish its 
freedom from liability.
    (b) The carrier denies liability for missing or damaged item packed 
in cartons because it did not pack the shipment and the cartons did not 
show outside damage. When a carrier accepts a shipment in apparent good 
order, it is responsible for damage to packed items, unless it can prove 
that the packing was improper and was the sole cause of the damage.
    (c) The carrier contends that the mildew damage occurred in NTS and 
not during its transport of the shipment. Mildew formation is more 
likely to occur in NTS than in transport. Unsupported by evidence, 
however, an allegation that mildew formation occurred during NTS

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does not rebut the established prima facie case of a carrier liability. 
A carrier must prepare an exception sheet and note any mold or mildew 
damage when the items were picked up from the NTS facility. The burden 
of proof is on the carrier to show that it was free from negligence and 
that the damage was due solely to the formation of mildew or mold during 
the NTS storage.
    (d) The carrier claims that damage is due to ``inherent vice.'' 
Although the carrier may allege that damage was due to ``inherent 
vice,'' the mere allegation of ``inherent vice'' is insufficient to 
relieve the carrier of liability. The burden of proof is on the carrier 
to establish that an ``inherent vice'' existed and that it was the sole 
cause of the damage claimed. Since the carrier can rarely establish this 
burden of proof, denial due to ``inherent vice'' is seldom acceptable.
    (e) The carrier contends that it was denied the right to inspect. 
Often a carrier will state that it made several attempts to make an 
inspection, but the shipper failed to keep the appointment. If such a 
case exists, the proper procedure for the carrier to follow is to 
contact the claims office for assistance in accomplishing the inspection 
within a timely manner. A carrier's efforts to obtain the inspection 
should be documented in the file by claims personnel. Lack of an 
inspection alone, however, does not relieve the carrier of liability and 
is insufficient to rebut a well-established prima facie case of 
liability.
    (f) The carrier denies liability on missing items because the items 
do not appear on the new inventory made at pickup from the NTS facility. 
When a carrier picks up a shipment from NTS and chooses to prepare a new 
inventory, it must use identical or cross-referenced numbers. If an 
article such as a chair or a lawnmower is missing, it must be indicated 
as ``missing'' on the new inventory. Whether or not a new inventory is 
made, an exception sheet must be prepared and the missing articles must 
be noted thereon. To relieve the carrier of liability, both the new 
inventory and the exception sheet must be signed by representatives of 
the NTS facility and the carrier.
    (g) The carrier denies liability due to ``act of God.'' An act of 
God is an event that could not have been prevented by human prudence. It 
is generally seen as an occurrence in which human skill or watchfulness 
could not have foreseen the disaster. The burden of proof is on the 
carrier to establish that an ``act of God'' existed and that it was the 
sole cause of the damage claimed. Since the carrier can rarely establish 
this burden of proof, denial due to an ``act of God'' is generally not 
acceptable. The carrier cannot avoid liability if it has been negligent 
in exposing the goods to potential danger or if it failed to take 
reasonable steps to reduce the extent of the injury once the danger was 
discovered.
    (h) The carrier contends that the claimant's repair estimate is 
excessive and that its own repair firm can do the job cheaper. A 
claimant has the right to select a repair firm provided the cost is 
reasonable and not in excess of the item's value. The carrier is liable 
for the reasonable cost of repairing damaged merchandise that includes 
labor, material, overhead, and other incidental expenses incurred in 
reconditioning or putting the goods in salable condition. If the carrier 
did not provide the claims office with an acceptable, lower estimate to 
use in adjudicating the claim, and if the claimant's estimate is 
reasonable, then the carrier is liable for the amount paid the claimant.
    (i) The carrier contends that liability should have been predicated 
on the agreed weight of a sofa and not a hide-a-bed. This argument only 
applies when carrier liability is based on weight. At the time the 
inventory is prepared, the carrier's driver must establish whether a 
sofa is merely a sofa, or one that converts into a bed. Failure to 
properly identify the item on the inventory does not relieve the carrier 
of liability for the greater weight of a sofa bed.
    (j) The carrier argues that it is not responsible for warpage, rust, 
etc., due to climatic changes. This argument does not relieve a carrier 
of liability unless the carrier offers substantial evidence to show that 
the damages resulted solely from unusual circumstances beyond its 
control, as with an ``act of God,'' or that it occurred while the 
property was in the hands of another contractor, as reflected upon a 
valid NTS exception sheet. The burden of

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proof is on the carrier to establish that the damage was not due to its 
negligence and that circumstances beyond its control were the sole cause 
of the loss. Because the carrier can rarely establish this, denial due 
to ``climatic changes'' is rarely acceptable.



Sec. 751.32  Forwarding claims files for offset action.

    (a) General. Claim files are forwarded with a recommendation for 
offset action when 120 days have passed since a demand and a response 
has not been received from the carrier or contractor. Files are also 
forwarded for offset action when an impasse is reached. An impasse 
occurs when legitimate efforts to collect the fully justified amount 
demanded have reached a standstill and the carrier has no valid basis 
for denial. Prior to forwarding files for offset action, claims 
personnel must ensure that timely notice has been given, that all 
necessary documents are included, and that the demand and any 
correspondence were mailed to the proper carrier or contractor at its 
correct address. When applicable, claims personnel must also ensure that 
an unearned freight packet is included.
    (b) Claim files forward to local contracting offices. Claims 
forwarded to local contracting offices for offset action include claims 
involving local moves and DPM shipments in which the origin and/or 
destination contractor is determined to be liable. When the contractor 
fails to reply to a demand within 120 days or fails to make an 
acceptable offer, the file should be forwarded to the local contracting 
office with a request for offset action.
    (c) Unjustified denials and inadequate settlement offers by carrier 
or contractor--(1) GBL carriers. If a GBL carrier or insurer has refused 
to acknowledge or respond to a demand within a reasonable time (usually 
30 days), if the claims investigating officer considers a valid claim to 
have been denied or not adequate settlement offered, or if settlement 
has been delayed beyond 120 days (see Sec. 751.32(a)), the claim shall 
be forwarded to the NLSC activity serving the geographical location 
recommending that set-off action be taken against the carrier or 
contractor. The 120-day period begins to run on the date initial demand 
is made on the carrier. The NLSC activity shall review the file and if 
the carrier liability is correctly computed, forward a copy of the GBL, 
copies of the DD Forms 1843 and 1844, SCAC code, and final demand on 
carrier to the Commanding Officer, Naval Material Transportation Office, 
Code 023, Bldg. Z-133-5, Naval Station, Norfolk, VA 23511 directing set-
off action against the carrier or contractor.
    (2) Nontemporary warehousemen. If a warehouseman or insurer has 
refused to acknowledge or respond to a claim within a reasonable time, 
if the claims investigating officer considers a valid claim to have been 
denied or no adequate settlement offered, or if settlement has been 
delayed beyond 120 days, the claim shall be referred to the NLSC 
activity serving the geographic location recommending set-off action be 
taken against the contractor. The 120-day time period begins to run on 
the date the initial demand was made. The NLSC activity shall review the 
file and if the warehouseman's liability is correctly computed, forward 
the file to the appropriate MTMC Regional Storage Management Office for 
set-off.



Sec. 751.33  Unearned freight packet.

    (a) Preparation. An unearned freight packet should be prepared when 
the loss or destruction of an item in shipment is attributable to a GBL 
carrier. Unearned freight packets should be addressed to the carrier, 
and not to the agents of GBL carriers, NTS contractors, or other 
contract movers. An unearned freight packet is required when a mobile 
home is lost or completely destroyed. An unearned freight packet 
includes:
    (1) A Request For Deduction of Unearned Freight Charges;
    (2) A copy of DD Form 1843;
    (3) A copy of DD Form 1844; and
    (4) A copy of the GBL.
    (b) Dispatch. The unearned freight packet is not dispatched to the 
NAVMTO, Norfolk until the carrier has paid its agreed liability or when 
offset has been accomplished.



Sec. 751.34  GAO appeals.

    (a) General. Sections 1 through 12 and 52 through 65 of Title 4, GAO 
Manual,

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Policy and Procedures Manual for Guidance of Federal Agencies, and 4 CFR 
parts 30-32 set forth procedures for carriers to appeal setoff action. 
Before a carrier can appeal a setoff action to GAO, the command 
requesting setoff action must make an administrative report to GAO.
    (b) Procedures for appeals. (1) The carrier must request appeal from 
the command requesting setoff action and request a GAO review.
    (2) The command requesting setoff action will review the appeal and 
if it is determined the setoff action was appropriate, will do an 
administrative report and notify the carrier when this has been 
accomplished.
    (3) The administrative report and complete claims file will be 
forwarded to the NLSC activity serving the geographic location for 
review prior to forwarding to GAO.
    (4) The complete claims package, including all correspondence with 
the carrier, will then be forwarded to GAO.
    (c) The administrative report and enclosures must support the setoff 
action.
    (d) GAO Manual. All NLSC activities have been provided a copy of a 
manual published by the Claims Group General Government Division, U.S. 
General Accounting Office entitled Procedures of the U.S. General 
Accounting Office for Household Goods Loss and Damage Claims. Other 
commands dealing with carrier recoveries should get a copy of the manual 
from the NLSC activity servicing the local area.



Sec. 751.35  Forms and instructions.

    Copies of all of the forms and instructions discussed in this part 
may be obtained if needed, from the Commanding Officer, Naval 
Publications and Forms Center, 5801 Tabor Avenue, Philadelphia, PA 
19120.