UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
OFFICE OF
THE INSPECTOR GENERAL
August 20, 1997
SUBJECT:
FROM:
TO:
Audit Report No. E1PMF6-05-01 15-7100277
Audit of Regional Laboratories
Michael Simmons
Deputy Assistant Inspector General
for Internal Audits
Mary Louise Uhlig
Acting Associate Administrator for
Regional Operations and State/Local Relations
Attached is the report on our audit of regional laboratories. The purpose of the audit was to
evaluate the planning and management of regional laboratories. We concluded that, along with
other EPA offices, the regional laboratories needed to improve the systems for planning,
measuring, and reporting on activities they performed in order to meet the requirements of the
Government Performance and Results Act. We also concluded that the laboratories needed a
stronger shared identity and national leadership.
ACTION REQUIRED
In responding to the draft report, your office provided corrective actions, with milestone dates,
for each recommendation. Therefore, no further response is required, and we are closing this
report in our tracking system. Please track all corrective actions in the Management Audit
Tracking System.
We have no objections to the further release of this report to the public.
We appreciate the cooperation you, your staff, and the regional laboratories provided during this
review. Should you or your staff have any questions, please contact Charles Allbeny, Audit
Manager, Northern Audit Division, at 312-353-4222 or Richard Hall, Headquarters Liaison at
202-260-5563.
Recycled/Recyclable • Printed with Vegetable OH Based Inks on 100% Recycled Paper (40% Postconsumer)
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EPA's Regional Laboratories
EXECUTIVE SUMMARY
INTRODUCTION
OBJECTIVES
RESULTS-IN-BRIEF
The Office of Inspector General (OIG) performed an audit of the
Environmental Protection Agency's (EPA) regional laboratories.
Although prior OIG reports have addressed the Agency's Office of
Research and Development laboratories, there have been no recent
reports concerning the management of regional laboratories.
The objectives of this audit were to:
• determine whether improvements were needed in how
regional laboratories' activities were planned and managed,
and
• identify areas where administrative processes among
regional laboratories could be streamlined.
To meet the Government Performance and Results Act of 1993
(the Results Act), EPA is taking steps to improve the processes for
planning, program evaluation, budgeting, and fiscal accountability.
The regional laboratories' current processes will not be adequate to
assist the Agency in meeting the Results Act. Areas for
improvement include: (1) preparing performance plans, (2)
measuring performance, (3) increasing accountability, and (4)
linking planning and performance to funding levels. See chapter 2
on page 5 for details.
EPA's regional laboratories need a stronger shared identity and
more active national leadership. Each regional laboratory has
historically operated independently of the others; however, there
are many similarities in their missions, goals, and contributions to
the Agency. A 1994 EPA report1 (1994 Laboratory Study)
recommended enhancing the role of the "central advocate" for the
'Research. Development, and Technical Services at EPA: A New Beginning. Report No.
EPA/600/R-94/122, July 1994.
i
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regional laboratories and re-evaluating which organizational
component should fill that role. Although the Office of Regional
Operations and State/Local Relations (OROS/LR) was designated
to perform this role, its ability to fulfill the responsibilities had
been limited. The absence of a shared identity among regional
laboratories and the limited scope of national leadership have
resulted in inefficient efforts to meet common needs. See chapter 3
on page 13 for details.
AGENCY ACTIONS
OIG EVALUATION
The Acting Associate Administrator for OROS/LR stated that
OROS/LR and the regional laboratory managers have joined the
Agency in its efforts to understand and implement specific
requirements and goals of the Results Act. The managers
recognize the importance of both planning and accountability and
will continue to bring their processes in line with the requirements
of the Results Act. Concerning the concept of shared identity for
the regional laboratories, OROS/LR will work with the laboratories
to achieve greater consistency and effectiveness through more
coordinated efforts. As the current reorganization of the Office of
Administrator is completed, its regional operations staff will work
to acquire the resources necessary to provide strong national
leadership for the broad scope of issues vital to the regional
laboratories. See pages 11 and 19 for specific actions the Agency
will take to address the findings and recommendations.
The Agency's actions, when completed, will address the findings
and recommendations in the report.
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Table of Contents
EXECUTIVE SUMMARY i
ABBREVIATIONS iv
CHAPTERS
1 INTRODUCTION 1
Purpose 1
Background 1
Scope and Methodology 3
Prior Audit Coverage 4
2 IMPROVEMENTS NEEDED TO MEET THE GOVERNMENT PERFORMANCE
AND RESULTS ACT 5
Government Performance and Results Act 5
Current Practices Need Improvement 6
Conclusion 11
Recommendations 11
Agency Actions 11
OIG Evaluation 12
3 REGIONAL LABORATORIES NEED A STRONGER SHARED IDENTITY AND
NATIONAL LEADER 13
Shared Identity 13
National Leadership 14
Illustrations of Need for National Leadership 16
Conclusion 18
Recommendations 19
Agency Actions 19
OIG Evaluation 19
APPENDICES
1 OFFICE OF REGIONAL OPERATIONS AND STATE/LOCAL
RELATIONS RESPONSE TO THE DRAFT REPORT 20
2 DISTRIBUTION 23
111
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Abbreviations
Government Performance and Results Act
Environmental Protection Agency
Research. Development, and Technical Services at EPA: A New
Beginning. July 1994, Report No. EPA/600/R-94/122
Office of Inspector General
Office of Regional Operations and State/Local Relations
Research Triangle Park
the Results Act
EPA
1994 Laboratory
Study
OIG
OROS/LR
RTF
IV
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CHAPTER 1
Introduction
PURPOSE
BACKGROUND
Regional Laboratories
The OIG performed an audit of EPA's regional laboratories.
Although prior OIG reports have addressed the Agency's Office of
Research and Development laboratories, there have been no recent
reports concerning the management of regional laboratories. Our
objectives were to:
• determine whether improvements were needed in how
regional laboratories' activities were planned and managed,
and
• identify areas where administrative processes among
regional laboratories could be streamlined.
A regional laboratory is located in each of the ten EPA regions.
The laboratories provide a range of scientific and technical services
for a wide variety of customers both internal and external to the
Agency. Customers include regional program offices and state and
local agencies. The laboratories' mission is to: (1) provide quality
scientific data, (2) integrate laboratory activities with field and
quality assurance partners, (3) maintain a fully equipped
laboratory, (4) maintain and enhance a technically and
scientifically skilled staff, and (5) advance the Agency's science
agenda.
The focus of the regional laboratories is on the application of
science policies and methods in support of regulatory programs,
monitoring programs, and special projects. The laboratories' main
role is to perform sample testing in support of various regional
programs. The regional laboratories perform many special
analytical services, which include fast turnaround and verification
analyses, nonstandard tests, and analyses requiring low detection
limits. Regional laboratories provide services other than analytical
support, including laboratory audits and certifications, methods
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development, field sampling, consulting and technical assistance,
data validation, expert witness testimony, and training.
Sources of
Analytical Services
Government
Performance
and Results Act
EPA regions have three potential sources of laboratory services.
The two main sources are the regional laboratories and the
Contract Laboratory Program. As already mentioned, the regional
laboratories perform many special analytical services. The
Contract Laboratory Program consists of a group of contractors
that provides routine analytical services in support of EPA's
Superfund effort. Non-Superfund programs may buy into these
contracts if funds are available.
If a regional laboratory or the Contract Laboratory Program does
not have a certain capability, a region can obtain analytical services
from private laboratories through blanket purchase agreements,
regional contracts, or small purchase requests. For example,
because Region 4 and the Contract Laboratory Program cannot
perform dioxin analyses, Region 4 contracts out for these services.
The Government Performance and Results Act (the Results Act)
was enacted on August 3, 1993, to provide for the establishment of
strategic planning and performance measurement in the Federal
Government. Other purposes of the Results Act include:
• initiating program performance reform by setting program
goals, measuring program performance against those goals,
and reporting publicly on their progress; and
• improving Federal program effectiveness and public
accountability by promoting a new focus on results.
The intent of the Results Act is to change the culture of Federal
agencies, from focusing on what agencies are doing to what they
are accomplishing. Implementing the Results Act would improve
agencies' planning, budgeting, and accountability processes,
linking them together so that planning drives budgeting. Actual
program results could also be monitored and used to influence
future planning.
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To achieve a strong link among planning, budgeting, and
accountability, the Results Act requires all agencies to produce
strategic plans, annual performance plans, and annual performance
reports. An agency's strategic plan will include a comprehensive
mission statement and general objectives covering the major
functions and operations of the agency. Annual performance plans
will include objective goals and describe the operational processes
and resources required to meet the goals. Annual performance
reports will assess the agency's performance versus the established
goals. The results will be used as a basis for future decisions on
programs and budgets.
SCOPE AND
METHODOLOGY Our audit focused on the regional laboratories' management and
administrative processes and the Office of Regional Operations and
State/Local Relations (OROS/LR) role as the central advocate for
the regional laboratories. We performed fieldwork in Regions 4, 5,
8, and 9; and at OROS/LR. We also obtained data from the other
six laboratories. We conducted fieldwork between July 8, 1996,
and June 13, 1997.
To accomplish our objectives, we reviewed applicable policies and
guidance and interviewed EPA officials in the regions visited and
OROS/LR. As criteria, we used the Results Act, relevant EPA
reports, Office of Administration and Resources Management
streamlining guidance, and Office of Management and Budget
information management policies.
Our first objective was to determine whether improvements were
needed in how regional laboratories' activities were planned and
managed. Through reviews of documentation and discussions with
laboratory, regional, and OROS/LR officials, we evaluated the
processes and management controls used to plan, schedule, track,
and report laboratory activities. Laboratory activities include
analytical tests, field sampling, and laboratory inspections and
certifications. We asked all ten regional laboratories about their
processes for scheduling, tracking, and reporting activities,
however we only requested data from the four regions visited. We
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also reviewed all ten laboratories' processes for determining their
annual funding levels.
Our second objective was to identify areas where administrative
processes among regional laboratories could be streamlined
including equipment purchases, development of data management
systems, and standard operating procedures. To accomplish this,
we asked laboratory officials from all ten regions about their
process for planning equipment maintenance and purchases. We
interviewed laboratory officials from the four regions visited
regarding their purchase and development of data management
systems.
We issued position papers to the regional laboratories and
OROS/LR on May 20, 1997. We met with both groups to discuss
the position papers, and incorporated their comments into the draft
report. The draft report was issued to the Acting Associate
Administrator for OROS/LR on June 25, 1997. Comments to the
draft report were received on July 29, 1997. The comments were
incorporated into the final report and included as Appendix 1.
We performed our audit in accordance with the Government
Auditing Standards. 1994 Revision, issued by the Comptroller
General of the United States, and included such tests as we saw
necessary to complete our objectives.
PRIOR AUDIT
COVERAGE There were no prior audits of EPA's regional laboratories related to
the objectives of our audit.
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CHAPTER 2
Improvements Needed to Meet The
Government Performance and Results Act
GOVERNMENT
PERFORMANCE
AND RESULTS ACT
To meet the Government Performance and Results Act of 1993
(the Results Act), EPA is taking steps to improve the processes for
planning, program evaluation, budgeting, and fiscal accountability.
The regional laboratories' current processes will not be adequate to
assist the Agency in meeting the Results Act. Areas for
improvement include: (1) preparing performance plans, (2)
measuring performance, (3) increasing accountability, and (4)
linking planning and performance to funding levels.
Section 4 of the Results Act requires Federal agencies to prepare
performance plans and reports. By September 1997 and annually
thereafter, each agency is required to prepare a performance plan
covering the program activities set forth in its budget. These plans
will:
• express objective, quantifiable, and measurable goals;
• establish performance indicators to be used in measuring or
assessing the relevant outputs, service levels, and outcomes
of each program activity; and
• provide a basis for comparing actual program results with
the established goals.
The Results Act also requires that starting March 31, 2000, each
agency will submit an annual report on program performance for
the previous fiscal year. The report will include the performance
indicators established in the plan along with the actual program
performance achieved as compared to the established goals. Also,
where a performance goal has not been met, the report will explain
why the goal was not met, the plans and schedules for achieving
the goal, and whether the goal is impractical or infeasible.
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To help ensure compliance with the Results Act, EPA established a
Planning, Budgeting, Analysis, and Accountability process.
Among other items, it included requirements for annual
performance plans and reports. While the regional laboratories are
not required to prepare their own plans and reports, they provide
important services to the program offices and need to improve their
planning process as EPA implements the Results Act. Consistent
planning methods throughout EPA, including the regional
laboratories, will simplify preparation of the Agency-wide annual
performance plans and reports.
CURRENT PRACTICES
NEED IMPROVEMENT
Preparing Annual
Performance Plans
The Results Act requires strong links among planning, reporting,
and budgeting; and increased accountability. To assist EPA in
meeting these requirements, regional laboratories, in conjunction
with program offices, will need to prepare annual plans with
objective goals and performance indicators and maintain consistent
data on results. Regional laboratories will then need to report to
regional and program management on actual achievements and
costs versus projected levels. Lastly, the laboratories will need to
base the funding they receive on planned activities and
performance results. Performing these activities will help the
regional laboratories and the Agency determine whether goals are
being met and resources are being used for priority activities.
Annual performance plans under the Results Act will include
objective goals and performance indicators. According to a 1994
EPA Subcommittee report2, regional laboratories generally lacked
the information required for effective planning. Only four often
regional laboratories prepared work plans that included goals and
indicators. Identifying these elements in annual plans will provide
the laboratories with a basis to compare to results and determine if
objectives are being achieved.
2Research. Development, and Technical Services at EPA: A New Beginning. Appendix F, "EPA
Laboratory Study: BSD Evaluation - Cross-Agency Subcommittee Final Report", Report No.
EPA/600/R-94/122, July 1994.
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In 1994, the Subcommittee identified a weakness related to
planning among the regional laboratories. There was a general
lack of readily available information, particularly in the areas of
resource management and future program needs. This information
was required to effectively plan for the future. The Subcommittee
recommended that EPA develop an integrated process to plan its
future, and evaluate its current, science and technical service
requirements. The ability to estimate current and future needs
would help the Agency develop performance plans. As of June
1997, EPA had not taken action to address the recommendation.
Regional laboratories prepared annual plans with varying levels of
detail.
• Half of the laboratories did not prepare written work plans.
Officials said planning specific activities was difficult
because the laboratories provided services in response to
changing regional needs.
• One laboratory prepared plans, but did not identify goals
and indicators. The work plans included narrative
descriptions of planned activities, based on regional
priorities.
• Four laboratories' work plans included goals and
indicators. For example, one region included the estimated
number of inspections and investigations. Another region
projected the work days required to complete certain
numbers of activities, such as training and technical
assistance. The plans did not include estimated levels of
analytical support the laboratories would provide, although
this was one of the laboratories' major activities.
Regional and laboratory officials said that it was difficult to
develop detailed work plans because the regional laboratories
provide a support function and must react to changing program
needs. However, the laboratories perform many of the same types
of functions every year. As a result, laboratory officials can
establish performance indicators and goals for some activities, with
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the recognition that the laboratories also fulfill special program
needs that are not easily quantified.
Performance indicators are particular values or characteristics used
to measure or assess relevant outputs, service levels, and outcomes
of program activities. Based on the audit, we identified two
potential indicators for the regional laboratories.
• One indicator could be the number of analytical tests
performed. Often regions, nine counted analytical
activities based on analyses, which represented one sample
through one instrument.3 A corresponding goal would be
that the regional laboratory would perform a certain number
of analyses in a fiscal year.
• Another indicator could be the number of laboratory audits.
Regional staff audit contract laboratories to ensure they are
properly analyzing samples. A related goal would indicate
the number of audits the region planned to conduct during
the year.
Measuring Performance To compare actual results to established goals on a national basis,
Results Consistently the regional laboratories need consistent data on achieved
performance levels. Comparing results to goals for analytical
support will be difficult because some regions include different
items in the counts of analytical activity. As a result, EPA will not
be able to determine the national performance level and whether
the laboratories are meeting established goals.
Laboratory officials included the standard analyses performed by
regional laboratory analysts in the analytical activity data. Also,
two of the ten regions included certain types of quality control
work in their data; the other eight did not. Including quality
control analyses adds significantly to the total analyses. For
example, Region 8 included quality control work in its data. In
fiscal year 1996, Region 8's total was over twice as high as Region
3Even if an instrument simultaneously tests for a number of elements, the activity is counted as one
analysis. However, there could be more than one analysis for each sample.
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Increasing Accountability
Through Reporting
4's (see table 1). This occurred although Region 8 had one of the
smallest regional laboratories while Region 4 had one of the
largest, based on the number of regional full-time equivalents.
Table 1: Regions Included Different
Activities in Data
Region
4
8
Includes Quality
Control Work
No
Yes
Total
Analyses
11,230
22,849
One method of measuring analytical activity is not recommended
over the other. However, because of the differences in measuring,
it would not be possible for the Agency to compare data across the
regions and to calculate total analytical activities versus the
projected level. The regional laboratories need to determine a
system for consistently measuring analytical activities. This will
allow determination of an EPA-wide total and comparison of
actual results to goals.
Accountability is a process for analyzing actual performance and
cost against goals and should focus on the Agency's
accomplishments relative to the commitments made in the annual
performance plan. Regional laboratories would increase their
accountability by preparing annual performance reports that relate
actual results and resources expended to objectives.
Seven of the ten regional laboratories prepared activity reports and
submitted them to regional or program management. These reports
varied in terms of the information included. Some of the reporting
regions compared actual accomplishments to planned activities,
while others only described completed activities. Five of the seven
regions included numerical data on the levels of actual or planned
performance.
The three remaining regional laboratories did not report laboratory
activities to regional or program management. Laboratory officials
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said that some regional and program management did not request
data on actual levels of performance or resources used because
they were satisfied with the services provided. Also, the programs
were not concerned about the cost of services as long as analyses
were performed on time. Staff members from one region said they
had not submitted reports since 1995 because management was
more interested in environmental results. In another region, the
laboratory previously submitted detailed quarterly reports to
program managers. Since the managers provided little feedback,
this practice was suspended.
The regional laboratories need to prepare performance reports to
show actual accomplishments and costs versus planned activities.
Preparing these reports will show whether the laboratories have
met their goals and where resources have been spent. Submitting
these reports to program and regional management will also
increase the regional laboratories' accountability.
Linking Funding to
Performance Plans
and Results
The Results Act emphasizes a strong link among planning,
reporting, and budgeting. EPA intends that performance plans and
prior years' results, including resources used, will be the basis for
future decisions on programs and budgets. However, only three of
ten regional laboratories used planned activities and prior years'
results as the basis for their budgets, while seven based their
budgets on historical amounts. Laboratory officials said that they
do not believe they have significant input into how much funding
they receive. This occurs because regional laboratories do not
have a specific appropriation. Instead, they are funded by other
program offices or through the Regional Administrators' offices.
In terms of basing budgets on historical amounts, an EPA report4
stated that: "The budget process should avoid focusing decisions
solely on the margin of the prior year's budget because this
discourages consideration of significant change or major
redirection." As the laboratories and EPA continue to implement
the Results Act and prepare performance plans and reports, the
4Managing For Results. The Planning, Budgeting, and Accountability Task Force, February 23, 1996.
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funding they receive should be based more on activities and less on
historical amounts.
CONCLUSION
RECOMMENDATIONS
AGENCY ACTIONS
The Government Performance and Results Act places new
requirements on Federal agencies for improving their planning,
budgeting, and accountability systems. Current regional laboratory
practices will not be adequate to assist the Agency in meeting the
Results Act. The regional laboratories can improve their planning
processes by working with program offices to prepare annual
performance plans that include goals and indicators and measuring
performance results consistently. The laboratories can: (1)
increase accountability by preparing annual performance reports
and (2) develop a stronger link between funding levels and
performance plans and results. Performing these activities will not
only help EPA meet the Results Act, it will improve the overall
management of activities and resources at the laboratories.
We recommend that the Acting Associate Administrator for
Regional Operations and State/Local Relations work with regional
laboratory management to:
2-1. Prepare, in conjunction with program offices, annual
performance plans that include goals and performance
indicators.
2-2. Develop a system that all regions will use to consistently
measure laboratory activities.
2-3. Prepare annual performance reports that compare goals
with actual accomplishments.
2-4. Base funding levels on performance plans and prior years'
results.
In responding to the draft report, the Acting Associate
Administrator for Regional Operations and State/Local Relations
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agreed with all the recommendations and stated that the regional
laboratories have taken, and will continue to take, action to address
the recommendations.
2-1. The regional laboratories are working with the program
offices, the Office of Planning, Analysis and
Accountability, and the Office of Regional Operations and
State/Local Relations to meet the requirements of the
Results Act. The regional laboratories have developed an
overall objective and sub-objectives, and are working on
specific performance measures and a performance plan.
The performance plan will be completed by the end of
fiscal year 1998.
2-2. The regional laboratories agree that a consistent
measurement system should be developed, and the issue
will be discussed at a meeting in September 1997.
However, they believe that it is important to develop a
system that is not only consistent and accurate, but also
reflects other factors and assumptions that need to be
considered when measuring the performance of regional
laboratories. A pilot evaluation system will be completed
by September 1998.
2-3. In accordance with the Results Act, the regional
laboratories will prepare annual performance reports that
will compare actual accomplishments with established
goals. The first report is due March 31, 2000, which will
address the accomplishments for fiscal year 1999.
2-4. The regional laboratories anticipate that funding decisions
will be based on accomplishment of goals as identified in
performance plans. The full system for linking planning,
budgeting, and accomplishments should be in place for the
development of the fiscal year 2002 budget. Interim efforts
will be made to assure maximum accountability.
OIG EVALUATION
The Agency's planned actions will address the recommendations.
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CHAPTER 3
Regional Laboratories Need a Stronger
Shared Identity and National Leadership
EPA's regional laboratories need a stronger shared identity and
more active national leadership. Each regional laboratory has
historically operated independently of the others, however, there
are many similarities in their missions, goals, and contributions to
the Agency. A 1994 EPA report5 (1994 Laboratory Study)
recommended enhancing the role of the "central advocate"for the
regional laboratories and re-evaluating which organizational
component should fill that role. Although the Office of Regional
Operations and State/Local Relations (OROS/LR) was designated
to perform this role, its ability to fulfill the responsibilities had
been limited due to resource constraints.
The absence of a shared identity among regional laboratories and
the limited scope of national leadership have resulted in inefficient
efforts to meet common needs. Development of a data
management system and procurement of capital equipment are two
examples of where uncoordinated efforts caused duplication of
effort. A stronger shared identity and more active leadership
would help the laboratories achieve efficiencies from their
collective efforts.
SHARED IDENTITY
Each of EPA's ten regional laboratories has historically seen itself
as a unique entity. Laboratory officials have no responsibility to
each other or to a national level office within EPA. Instead, each
regional laboratory reports to its respective Regional
Administrator. At the same time, regional laboratories share
similarities in their missions, goals, and contributions to EPA.
Each provides a wide range of technical support and assistance
5Research. Development, and Technical Services at EPA: A New Beginning. Report No.
EPA/600/R-94/122, July 1994.
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services to regional program offices, state and local environmental
agencies, and tribal units for use in environmental and enforcement
decision-making. Specific activities include sample analysis,
method development, and laboratory inspection and certification.
Regional laboratories are not, and should not be, identical in their
size, structure, or method of delivering services. Geographic and
program variations mandate that each laboratory has the flexibility
to meet unique requirements. However, the laboratories need to
accept and embrace that there are significant similarities in the
functions they perform. The regional laboratories prepared a draft
vision statement that indicated that, more and more, solutions to
environmental problems can be achieved only through the
collective efforts of all stakeholders. A stronger shared identity
and national leadership will assist the laboratories in considering
not only their regional needs, but national needs that can be met
through coordinated efforts.
NATIONAL
LEADERSHIP The laboratories continue to need stronger national leadership.6 In
the 1994 Laboratory Study, EPA concluded that it needed to
strengthen the Headquarters advocacy for the regional laboratories.
This would, in essence, place regional laboratories on a par with
national program offices. This organization would serve a two-
fold role. First, it would represent the regional laboratories within
Agency-level issues. These would include discussions concerning
allocation of resources. Second, the organization would serve as a
focal point for regional laboratory functions. This would include
identifying efficiencies related to coordination of laboratory
functions and encouraging cooperation among the laboratories.
However, according to EPA officials, the expanded role EPA
envisioned has not been fulfilled due to resource constraints.
The 1994 Laboratory Study listed the following activities among
the central advocate's proposed roles:
6The regional laboratories have referred to this role as the "central advocate". However, in the context of
this report, we will refer to it as "leadership" to better include all aspects of the envisioned role.
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• provide consensus building for the effective and efficient
use of resources to meet support requirements;
• facilitate communications among the laboratories, the
Administrator, and program offices;
• ensure that senior management understood how the
laboratories' mission integrates into EPA's overall
scientific mission;
• represent the laboratories during budget and strategic
planning efforts; and
• provide leadership for the laboratories promoting national
consistency.
The study recommended that OROS/LR continue as the central
advocate with enhanced management and budget support.
However, according to an OROS/LR official, it was not able to
fulfill this enhanced role due to limited resources. The
OROS/LR's activities for regional laboratories had been limited to
budget justification and distribution of resources for capital
equipment.
The regional laboratory managers believe that stronger national
leadership is needed. The managers provided the following areas
of deficiencies which highlight the need for stronger leadership:
• liaison between the laboratories and Headquarters program
offices, resulting in less than full integration of the regional
laboratories into the Agency's science program,
• communication between Headquarters and the laboratories
concerning emerging issues that may affect its operation
and results in under-utilization of resources,
• advocacy or leadership when budget and staffing levels are
addressed,
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• promotion, at the national level, of the regional
laboratories' functions and contribution to the Agency, and
• recognition of the role that regional laboratories play in
enforcement, monitoring, and agency initiatives.
OROS/LR is currently undergoing a reorganization and
redefinition of duties. As part of the reorganization, Agency
management has decided that regional laboratory leadership will
remain with the regional operations staff in the Office of the
Administrator. As EPA implements the reorganization, it needs to
determine what role the regional operations staff will perform. In
doing so, it is essential that the regional operations staff provide
stronger national leadership.
ILLUSTRATIONS OF
NEED FOR NATIONAL
LEADERSHIP
The absence of: (1) a shared identity and (2) an effective national
leadership have resulted in inefficient use of resources. Attempts
to develop data management systems within regional laboratories
and the procurement of capital equipment are two examples of
where national leadership may have resulted in a more efficient use
of resources. A stronger shared identity and national leadership
will assist the laboratories in considering not only their individual
needs, but how their needs impact and overlap the needs of other
laboratories.
Data Management
Systems
Each regional laboratory has independently purchased, or
developed, its own data management system. While actual use
varied, each laboratory's data management system had the
capability to perform some similar functions. In 1992, EPA's
Research Triangle Park (RTF) and regional laboratories attempted
to develop a common system that would address the core needs of
all of the laboratories. However, in spite of its efforts and
investments, EPA does not have a data management system which
meets the laboratories' needs.
The RTF system was designed to contain a core set of functions
that all of the laboratories needed such as project management,
sample tracking, and analysis scheduling. The data management
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EPA's Regional Laboratories
system was provided to interested regions. However, only a few
regions adopted it as the others felt the system was not adequate.
Some of the regional laboratories felt that this system did not meet
the needs already met by current systems, was not user friendly,
and that it had flaws. For example, the system did not: (l)meet
biologists' needs, (2) electronically transfer data, or (3) generate
reports. As a result, regional data management needs have been
met through several different efforts.
A comparison of Region 5's and 9's systems shows the variations
in how the systems are used and the related costs.
• Region 5 uses its system to track workload, track samples,
generate reports, and upload information from instruments.
Region 9 currently only uses its system to log in samples.
• Region 5 obtained its system at no cost from RTF. Region
9 purchased a commercial system for about $10,000.
• Region 5 had recently modified its system to expand its
capabilities. Region 9 was hiring computer support to learn
the capabilities of its system.
The comparison of the systems shows the differences that exist
throughout regional laboratories. Both regions spent time and
resources trying to get a reliable system in operation. A stronger
national leadership would prevent further duplication of effort in
the purchase, development, or modifications of systems needed to
meet the regional laboratories' core needs. This leadership could
facilitate communication among the laboratories to determine the
universal needs for a system, capabilities that had already been
developed, and on-going regional developments. Coordination of
data management system development would result in a more
consistent national process for tracking laboratory activities.
Equipment Purchases Regional laboratories' capital equipment purchases were made
based on regional rather than national needs. As a result, regional
laboratories have the potential for inefficient use of equipment
resources. If equipment purchases were better coordinated,
regional laboratories could reduce the potential for purchasing
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equipment that would not be fully used. EPA and the regional
laboratories have also recognized the need for better coordination,
but have not taken action to improve it.
While OROS/LR was responsible for ensuring proper use of the
capital equipment funds, it did not centrally manage the equipment
purchases, nor did it require the regional laboratories to submit
information on planned purchases and the rationale for those
purchases. In December 1996, the OROS/LR began developing a
tracking system to show equipment purchased since 1992. An
OROS/LR official stated that requiring laboratories to submit the
information increased their accountability for the funds. However,
OROS/LR's tracking system only identifies past equipment
purchases and does not account for planned purchases. As a result,
the current method of tracking will still not prevent regional
laboratories from purchasing duplicate equipment that will be
underutilized.
Regional laboratories have recognized that there may be a more
efficient way of using equipment. A draft vision statement for the
regional laboratories indicated that the regions would coordinate
workload, equipment, and expertise among themselves to assure
the most efficient and highest quality service. Under this vision,
regional laboratories might use equipment resources more
efficiently through coordination of equipment purchases. National
leadership for the regional laboratories could help the regional
laboratories identify a better way to use resources to meet support
requirements. This leadership could bring the laboratories together
to recognize there are commonalities in their work and that they
can provide support not only to their regions but also to each other.
CONCLUSION
EPA's regional laboratories need a stronger organizational identity
and national leadership. Each regional laboratory has historically
operated independently of the others, however, there are many
similarities in terms of their missions, goals and contributions to
the organization. The enhanced national leadership role EPA
envisioned is currently not being fulfilled. A stronger shared
identity and national leadership could help regional laboratories
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improve coordination of their activities to reduce duplication of
effort and achieve efficiencies in the use of resources.
RECOMMENDATIONS
We recommend that the Acting Associate Administrator for
Regional Operations and State/Local Relations:
3-1. Work along with the regional laboratories to complete their
efforts to develop a common vision and mission statement.
3-2. Work with regional laboratory management to identify the
appropriate responsibilities for the national leader.
AGENCY ACTIONS
In responding to the draft report, the Acting Associate
Administrator for OROS/LR agreed with the recommendations and
described actions to address the recommendations.
3-1. The regional laboratory vision and mission statements
should be completed by January 1998.
3-2. During the current reorganization, OROS/LR discussed
with the Regional and Deputy Regional Administrators and
regional laboratory directors the specific responsibilities for
the national leader. Within one month of finalizing the
reorganization plan, a work plan will be developed to
reflect regional operations staff activities in support of
regional laboratory operations.
OIG EVALUATION
The Agency's planned actions will address the recommendations.
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Appendix 1
Page 1 of3
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
Office of Regional Operations
and State/Local Relations
MEMORANDUM
DATE: July 29, 1997
SUBJECT: Response to the Draft Audit Report No. E1PMF6-05-0115, Audit of
Regional Laboratories
FROM: Marylouise M. Uhlig
Acting Associate Administrator
TO: Michael Simmons
Deputy Assistant Inspector General for Internal Audits
On behalf of the Regions and OROS/LR, I want to thank you for the opportunity to
review the Draft Audit Report No. E1PMF6-05-0115, Audit of Regional Laboratories. Charles
Allberry, Audit Manager, Northern Audit Division and his staff conducted a highly professional
review of the planning and management processes of the Regional laboratories. Evaluations of
this kind are very useful to management serving as important tools in our efforts to improve and
streamline operations.
The Office of Regional Operations and State/Local Relations (OROS/LR) and the
Regional Science and Technology (RS&T) Managers have joined with the Agency in its efforts to
understand and implement the specific requirements and goals behind the Government
Performance and Results Act (GPRA). We recognize the importance of both planning and
accountability and will continue recent ongoing efforts to bring our processes in line with GPRA
requirements. Supporting the concept of a shared identity for the Regional laboratories, the
Regional Operations Staff will work with the Regions to achieve greater consistency and
effectiveness through more coordinated efforts across the Regional laboratories. As the
reorganization of portions of the Office of the Administrator, including the Regional Operations
Staff (ROS), is implemented, the ROS will work to acquire the resources (FTE) necessary to
provide strong national leadership for the broad scope of issues vital to the Regional Science and
Technology organizations.
Note: The original response was signed by Bettina B. Fletcher for Marylouise M. Uhlig.
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Appendix 1
Page 2 of3
In response to your specific recommendations, we offer the following comments, planned
corrective actions and time frames for accomplishing these remedies.
Recommendation 2-1
The Regional laboratories are working with Program components, the Office of Planning,
Analysis and Accountability, and OROS/LR to meet the requirements of GPRA. The RS&T
organizations have developed an RS&T Objective under Agency Goal 8, Sound Science, and a
draft Profile Planning Baseline to accompany the Objective. Also, an RS&T GPRA Workgroup
comprised of representatives from each RS&T, have developed Sub-objectives that further define
the RS&T Objective and provide specific Performance Measures. The RS&T GPRA Workgroup
will continue to respond to all Agency GPRA requirements for implementation. The next step
will be the development of the Performance Plan with Goals and Performance Indicators. The
time frame for complete implementation of this recommendation according to the Agency's GPRA
schedule will be the end of FY 1998 for FY 1999.
Recommendation 2-2
The RS&Ts have had numerous discussions concerning the issue of measuring laboratory
activities consistently across the Regions. The RS&Ts agree that a consistent measurement
system should be developed and this issue will be on the agenda for the fall RS&T meeting in
September, 1997. However, the RS&Ts believe that it is important to develop a laboratory
activities measurement system that is not only consistent and accurate, but also reflects numerous
other factors and assumptions which impact any algorithm used to measure laboratory
performance. Sample matrix complexity, programmatic requirements, temporal sample loading
patterns, data quality objectives (e.g. from enforcement-quality requirements to initial site
screening), appropriate quality assurance levels all significantly impact the number of samples
analyzed by a laboratory. A mechanism to measure Regional laboratory activities, including
consideration of the additional factors, will be prepared for pilot evaluation by September, 1998.
Recommendation 2-3
In accordance with GPRA, the RS&Ts will join the Agency in preparing annual
Performance Reports that compare actual accomplishments with established goals. Laboratory
performance will be an important element of these reports. The first steps in this process have
already been taken with the development of the RS&T Objective, Sub-objective and Performance
Measures under GPRA. Implementation of this recommendation will follow the Agency GPRA
requirements with the first Annual Performance Reports due March 31, 2000 addressing
accomplishments for FY 1999.
Recommendation 2-4
The RS&Ts anticipate that funding decisions will be based on the accomplishment of
Goals as outlined in their respective Performance Plans. Performance Plans with their
Performance Indicators will be incorporated with the Annual Performance Reports and Program
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Appendix 1
Page 3 of3
Office guidance concerning areas of investment and disinvestment to establish outyear funding
requests. Implementation of this recommendation will follow the Agency schedule which calls for
the completion of Annual Performance Reports by March 31, 2000 addressing the
accomplishments of FY 1999. Accordingly, the full GPRA system to link planning and budgeting
should be in place for the Regional laboratories for development of the Agency's FY 2002
budget. Interim efforts will be made to assure maximum accountability of Regional laboratories
as rapidly as possible.
Recommendation 3-1
OROS/LR is actively engaged with the RS&T managers to complete development of a
common vision and mission statement for the Regional laboratories. The vision and mission
statements will be discussed with Senior Regional management as well as Headquarters Program
Offices to assure that there is a shared understanding and support for the functions which the
Regional laboratories can and should provide for the Agency. We anticipate that the vision and
mission statements should be in place by January, 1998.
Recommendation 3-2
OROS/LR, in the context of recent Office Reorganization activities, initiated a dialogue
with both the RS&T managers and Regional and Deputy Regional Administrators concerning the
specific responsibilities for the national leader of the RS&Ts. The need for improved coordination
among Regional laboratories for greater efficiency and effectiveness is recognized and will be
incorporated in the activities of the successor organization, the Regional Operations Staff (ROS)
The scope of the functions which can be carried out will be dependent upon the staffing levels
which can be established for this activity.
OROS/LR's has a long history with the Regional laboratories; this experience and
expertise will continue through the Regional Operations Staff. There is a strong commitment on
the part of the Office of the Administrator, including the Regional Operations Staff, to provide the
National leadership to the Regional laboratories to maximize their ability to support the Agency's
mission for protection and improvement of public health and the environment. As soon as the
Office of the Administrator Reorganization is finalized, a work plan will be developed for
Regional Operations Staff activities in support of the RS&T operations. This work plan will
reflect discussions with RS&T managers, Regional Administrators and Deputy Regional
Administrators and will define the responsibilities of this National leadership role. The draft
workplan will be developed within one month of the completion of the Reorganization.
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Appendix 2
Page 1 of 1
DISTRIBUTION
Headquarters
Acting Associate Administrator for Regional Operations and
State/Local Relations (1501)
Assistant Administrator, Office of Research and Development (8101)
Audit Followup Coordinator, Office of the Administrator (1104)
Agency Followup Official (3101)
Attn: Assistant Administrator, OARM
Agency Followup Coordinator (3304)
Attn: Director, RMD
Associate Administrator for Congressional and Legislative Affairs (1301)
Associate Administrator for Communications and Public Affairs (1701)
Headquarters Library (3404)
Office of Inspector General
Inspector General (2410)
GAO Issue Area Planner
Divisional Inspectors General
Regional Offices
Regional Administrators
Regional Laboratory Directors
Regional Libraries
,. -23;>"- >-•"- <-j
,i .. Report No. 7100277
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U.S. Environmental Protection Agency
Region 5, Library (PL-12J)
77 West Jackson Boulevard. 12th Ftonr
Chicago, IL 60604-3590
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