A spokesman for the inspector general's office at the Department of the Interior said that under federal procedure, objections to an audit's findings must be done in writing and be delivered on time.

Thus, even though the state agency now contends that more than half the firearms it lent out were actually nonworking replicas of guns, that position is not reflected in the audit report because the official departmental response to the draft audit doesn't make that point.

The second, supplemental response from the Natural Resources Police does make that assertion, but the inspector general's office said it did not receive the document and it was not reflected in the final report.

Griffin and Johnson asserted that the state has had an effective inventory control system for the firearms all along, even though they acknowledged the firearms weren't recorded in the state's official system for tracking capital equipment.

"We're not threatening public safety. We have a very good inventory system," Griffin said.

However, the auditors also found that the Department of Natural Resources did not conduct an annual inventory of so-called sensitive items, including firearms, in either the 2010 or 2011 budget years, as required by the state Department of General Services.

"The department has increased the risk that equipment purchased with federal funds or license revenues could be lost, misplaced or used for other unauthorized purposes," the auditors said.

Mark Hoffman, director of finance and administrative services at the natural resources department, acknowledged that is true. "We are out of sync on our inventory process," he said, blaming a staff reshuffle due to a lost job position.

But Johnson said the police kept their own inventory outside the formal sensitive items count — a rebuttal that was not given to auditors in writing. The chief said the police are working to integrate its system with the legally prescribed process for sensitive items.

Butch Janeczek, senior firearms instructor with the Baltimore County Game and Fish Protective Association, said his impression is that the state keeps careful track of the guns. He said he recently became the custodian of 11 state-issued firearms — six operational and five nonfunctional — that are kept in a safe at the club.

"I've had them less than six months, and I've already been inventoried twice," he said. For the inventory, he said, a state official has visited his site and done a physical inspection, Janeczek said.

While many of the facts surrounding the program remain in dispute, one thing is clear: The department did not show auditors sufficient documentary evidence — either in the original audit or its response to the draft — to persuade them that the program is being run effectively and without diverting federal funds.

Nevertheless, Griffin said, he stands by the hunter education program's results and its handling of firearms.

"We have never in the history of this program had one stolen or used in a criminal activity," he said.