UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

                       OFFICE OF INSPECTOR GENERAL
                           SOUTHERN DIVISION, SUITE 276
                           I 375 PEACHTREE STREET. N.E.
                             ATLANTA. GEORGIA 3O3O9
                                                             REGIONAL OFFICE:
                                                             EARI.E CABELL BLDG , RM 2F5O
                                                             DALLAS. TX 75242
                                                             
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                REPORT ON  INTERIM  AUDIT  OF
TENNESSEE DEPARTMENT OF HEALTH AND ENVIRONMENTAL SERVICES
           DIVISION  OF SOLID  WASTE MANAGEMENT'S
  ADMINISTRATION OF ITS SUPERFUND COOPERATIVE AGREEMENT
 WITH EPA UNDER THE COMPREHENSIVE ENVIRONMENTAL RESPONSE
          COMPENSATION AND LIABILITY  ACT OF  1980
                GRANT NUMBER V004485-85-5
      FOR  THE  PERIOD MARCH 27,  1985 TO JUNE  30,  1987
                 BRANDON,  SMITH AND JONES
               CERTIFIED PUBLIC ACCOUNTANTS

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         TENNESSEE DEPARTMENT OF HEALTH AND ENVIRONMENTAL SERVICES
                     DIVISION  OF  SOLID  WASTE MANAGEMENT
               FOR THE  PERIOD  MARCH  27,  1985 TO  JUNE  30,  1987
                             TABLE OF CONTENTS
                                                                      PAGE
Background	     1


Auditor's Report on Cost Incurred	,	     2
Exhibit A - Summary of Costs Incurred, Accepted,
              Questioned and/or Set-Aside	    3-5
Auditor's Report on Compliance	    6


Auditor's Report on Internal Controls	   7-8


Grantee1 s Comments	   9-14


Auditors' Response to the Grantee's Comments	  15-17


Appendix A - Grantee's Comments on Work Time Units

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        TENNESSEE DEPARTMENT OF HEALTH AND ENVIRONMENTAL SERVICES
                   DIVISION OF  SOLID WASTE MANAGEMENT
BACKGROUND

On December  1),  1980,  Public Law 96-510,  the Comprehensive Environmental
Response, Compensation,  and Liability Act  (CERCLA) was enacted by Congress.
CERCLA, commonly known as  "Superfund," was passed to protect public health
and  the environment  from hazardous  substances by authorizing Federal action
to respond to  the  release, or  threatened  release, from any source, including
abandoned hazardous  waste  sites, into any  part of the environment.  A Trust
Fund was established for Federal and State governments to respond directly
to any problems at uncontrolled hazardous waste disposal sites, not only
in emergency situations, but also at sites where longer term permanent re-
medies are required.

The blueprint  for  the  Superfund program under CERCLA is the National Con-
tingency Plan  (NCP),  first published in  1968, as part of the Federal Water
Pollution Control  Plan.  The NCP laid out  three types of responses for in-
cidents involving  hazardous wastes  which  are: immediate removal, planned
removal, and remedial  response.  The first two types of responses were
modifications  of an  earlier program under  the Clean Water Act.  Remedial
response was intended  to deal  with  the longer term problem of abandoned or
uncontrolled sites.   NCP changes effective February 18, 1986, established
one broad categroy of  removals, thus eliminating the distinction between
immediate and  planned  removals.

CERCLA provides for  compiling  a National  Priority List (NPL) of hazardous
waste sites for remedial action.  In October 1981, EPA compiled an interim
priorities list of 115 hazardous waste sites.  The sites were nominated by
the EPA Regional Offices and the States,  primarily on the basis of poten-
tial threat to the public health.   Also,  the threat to the environment was
considered.  In September  1983, EPA published the first NPL, which con-
sisted of 406  sites.

CERCLA Section 104(c)(3) provides that no remedial actions shall be taken
unless the State in  which the  release occurs first enters into a contract
or cooperative agreement with  EPA,  with assurance of payment of 10 or 50
percent of remedial  costs.  The State must agree to a cost-share of 10
percent if the site  was  privately owned.  At publicly owned sites (one
owned by the State or  a  political subdivision thereof), the State is re-
quired to pay  50 percent of all remedial  action costs.  Cooperative
agreements for remedial  investigations, feasibility studies, and remedial
designs can be funded  up to 100 percent by EPA.

TDHES had the  responsibility of identifying and ranking sites which posed
a risk to the  public or  the environment and performance of remedial in-
vestigation,  design  and  cleanup at  hazardous waste sites.  During the
audit, TDHES was actively involved  with the Cooperative Agreement with
EPA for remedial activities.

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                                  BRANDON, SMITH AND JONES
                                   CERTIFIED PUBLIC ACCOUNTANTS
                                           SlTTE 1210
                                      100 NORTH MAIS- BCILOINC
                                    MEMPHIS, TENNESSEE 38103-5066

QTHA L BRANDON. S« . CPA I1921-198OI                                                               I9°" 526-5956
HARVEY V. SMITH. CPA
ESNESt JONES. JR.. CPA

          Mrs.  Kathryn Kuhl-Inclan
          EPA  Office of Inspector General
          Audits  and Investigations
          Southern Division - Suite 276
          1375 Peachtree Street, N. E.
          Atlanta, Georgia  30309

          Dear Mrs,  Inclan:

          We have examined the costs incurred by the Tennessee Department of Health
          and  Environmental Services (TDHES)  Division of Solid Waste Management re-
          lated to the Cooperative Agreement  Grant  Number VQ04485-85-5 for the period
          March 29,  1985 through June 30, 1987 as detailed in Exhibit A.  Our ex-
          amination  was performed in accordance with generally accepted auditing
          standards  and the Standards for Audit of Governmenta 1 0rganiza.tion s, P r o-
          grams,  Activities,  and Functions (1981  revision).  Accordingly, our exami-
          nation  includes such tests of the accounting records and such other
          auditing procedures as we considered necessary in the circumstances.

          As part of our examination, we determined the allowability of costs claimed
          under the  project in accordance with the provisions of the cooperative
          agreements and applicable Federal regulations.  Exhibit A sets forth the
          costs which we questioned and/or set aside in this regard and includes an
          explanation of the  reasons such costs were questioned and/or set aside.

          In our  opinion, subject to the effects of EPA's ultimate resolution of
          the  questioned and/or set aside costs referred to in the preceding para-
          graphs, Exhibit A presents fairly the costs incurred by the Tennessee
          Department of Health and Environmental Services Division of Solid Waste
          Management under the cooperative agreements with EPA on the basis de-
          scribed above.

          The  summary of costs incurred, accepted,  questioned and/or set-aside
          (Exhibit A) was prepared on the basis of regulations and criteria estab-
          lished  by  the U. S. Environmental Protection Agency relating to Superfund
          Cooperative Agreements pursuant to Public Law 96-510.  Accordingly, Exhi-
          bit  A is not intended to present fairly the financial position and results
          of operations in conformity with generally accepted accounting principles.

          This  report is intended for use in connection with the cooperative agree-
          ments to which is refers and should not be used  for any other purpose.
         January  21,  1988

                                              -2-

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                                                                 EXHIBIT A
                                                                 Page  1  of  3
         TENNESSEE DEPARTMENT OF HEALTH AND ENVIRONMENTAL SERVICES
                     DIVISION OF SOLID  WASTE MANAGEMENT
      SUMMARY  OF  COSTS  INCURRED,  ACCEPTED,  QUESTIONED AND/OR SET-ASIDE
            FOR THE PERIOD MARCH 27, 1985 THROUGH JUNE 30, 1987
                         GRANT NUMBER V004485-85-5
                          Incurred*    Accepted    Quest ioned   Set-Aside   Notes
Personnel
Fringe benefits
Travel
Equipment
Supplies
Contractual
Indirect charges
Others
$ 387,896
89,015
3,279
3,566
12,691
156,525
60,094
47,139
$ 293,351
69,334
2,082
3,566
12,691
30,900
34,791
45,659
$ 94,345 $
19,681
1,197
-
-
125,625
25,303
1,480
1
1
2


3
4
5
    TOTAL
492,574
$125.625
Less:  EPA payments
  made through June 25,
  1987
770,221
Balance Due EPA
-The amount incurred represent expenditures reported through June 30, 1987.
                                    -3-

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                                                                 EXHIBITA
                                                                 Page 2 of 3
          TENNESSEE DEPARTMENT OF HEALTH AND ENVIRONMENTAL SERVICES
                     DIVISION OF  SOLID WASTE MANAGEMENT
      SUMMARY OF COSTS INCURRED,  ACCEPTED, QUESTIONED AND/OR SET-ASIDE
               FOR THE PERIOD MARCH 27, THROUGH JUNE 30,  1987
                          GRANT NUMBER V004485-85-5
                           NOTES TO THE STATEMENTS
Note  1 - Personnel andFringe Benefits

We have questioned $94,345 of personnel cost which consist of the f-^1 lowing:

     A.  A portion of the director's salary was charged to the
         grant, $29,568.  We believe that the director is an
         overhead type employee and the salary should be charged
         accordingly.  Also, we noted that the project was being
         maintained by the project manager which administered
         the entire grant.                                          $ 29,568

     B.  Cost charged for a Chemist 2 which was not approved by
         EPA.                                                          4,035

     C.  Cost claimed for an Environmental Specialist 2 sub-
         sequent to this person being transferred out of this
         program (June I, 1985).                                      17,923

     D.  Cost charged for a Chemist 2 ($37,905) and secretary
         ($4,914) which was not associated with the Superfund
         Program.                                                     42,819
                TOTAL PERSONNEL COST QUESTIONED                     $ 94.345

We have also questioned the fringe benefits related to the
personnel costs questioned.                                         $ 19.681

Note 2 - Travel

We have questioned $1,197 in travel costs because $625 was charged for the
director and the State was unable  to document $572.

Note 3 - Professional Services

We have set-aside $125,625 in professional services incurred.  This amount
represents laboratory services performed by the State utilizing  the time
unit value method.  We were unable to express an opinion on  the  time and
motion study which was used in allocating this costs.  Therefore, we have
set-aside the $125,625 pending a technical review by EPA as  to the reason-
ableness of the cost.

Note 4 - Indirect Charges

We have questioned $25,303 of indirect costs incurred.  A total  of $7,291
was related to questioned cost in  Notes 1, 2, 3, and 5 during the fiscal
years of June 30, 1985 and 1986.   The difference or $18,012  was  incurred
during fiscal year June 30, 1987.  We have questioned this amount because
the indirect costs were not based  upon final approved rates  during this
period as required by OMB Circular A-87.

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                                                             EXHIBIT A
                                                             Page 3 of 3

          TENNESSEE  DEPARTMENT OF HEALTH  AND ENVIRONMENTAL  SERVICES
                    DIVISION OF SOLID  WASTE  MANAGEMENT
     SUMMARY  OF  COSTS  INCURRED, ACCEPTED,  QUESTIONED  AND/OR SET-ASIDE
           FOR THE PERIOD MARCH  27, 1985 THROUGH JUNE 30,  1987
                        GRANT  NUMBER V004485-85-5
                         NOTES TO THE STATEMENTS
Note 5 - Others

We questioned $1,480 of other costs incurred during the project period.
The State claimed $51 for printing, $754 for rent and $675 for grants and
subsidies.  The State was unable to provide documentation (invoices, can-
celled checks, etc.) to substantiate printing and grants/subsidies costs.
OMB A-87 states that all costs charged to a grant must be adequately docu-
mented.  We have questioned 26 days of rent costs charged to the grant
for March 1985 or $754 because the effective date of the grant was
March 27, 1985.
                                     -5-

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OTHA1- BRANDON. SR. CPA (1921-19801
HARVEY L SMITH, CPA
ERNEST JONES. JR . CPA
 BRANDON, SMITH AND JONES
   CERTIFIED PUBLIC ACCOUNTANTS
           SUITE 1210
      100 NORTH MAIN BUILDING
    MEMPHIS, TENNESSEE 38103-5066


        March  22, 1988

AUDITOR'S REPORT ON COMPLIANCE
                                                                                   [SOU S2S-S9S6
         Mrs.  Kathryn  Kuhl-Inclan
         EPA Office  of Inspector General
         Audits  and  Investigations
         Southern  Division - Suite 276
          1375  Peachtree Street,  N. E.
         Atlanta,  Georgia  30309

         We have examined the summary of costs incurred,  accepted, questioned and/or
         set-aside of  Tennessee  Department of Health and  Environmental Services
         (TDHES) Division of Solid Waste Management under Grant Number V004485-85-5
         for the period March 27, 1985 through June 30, 1987, and have issued our
         report  dated  January 21, 1988.   Our examination  was made in accordance with
         generally accepted auditing standards and, accordingly, included such tests
         of the  accounting records and such other auditing procedures as we considered
         necessary in  the circumstances.

         In our  opinion, the tested transactions of TDHES complied with the material
         terms and conditions of the grant award and the  tested grant financial re-
         ports were  accurate and complete insofar as it was reasonable and practical
         to determine,  except as noted in the following paragraphs.  Further, nothing
         additional  came to our  attention as a result of  the foregoing procedures to
         indicate  that  TDHES had not complied with the material terms and conditions
         referred  to above, and  that the grant financial  reports were not accurate
         and complete  within reasonable  and practicable limitations for those trans-
         actions not selected for testing.

         Letter  of Credits

         During  our  review, we noted the drawdowns on the letter of credit are based
         on estimating  the expenditures  in lieu of actual costs incurred.  The
         Letter  of Credit-Treasury Financial Communication System Recipients Manual
         states  in part that the organization should request funds based on immediate
         disbursement  needs whenever possible and disburse funds as soon as possible
         to minimize the Federal cash on hand.

         Recommendation

         We recommend  that all drawdowns should be based  on actual expenditures.

         The final determination regarding allowability or unallowability of costs
         as a  result of our examination  will be made by EPA.
         Sincerely
                                              -6-

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                                  BRANDON, SMITH AND JONES
                                   CERTIFIED PUBLIC ACCOUNTANTS
                                           SUITE 1210
                                      100 NORTH MAIS BUILDING
                                    MEMPHIS, TENNESSEE 38103-5066
OTHAL BRANDON. SR . CPA i'92I I98OI                   March 22   1988                             I9OII SS6-S9S6
HARVEY L SMITH. CPA                            '         '
EflNEST JONES. JH . CPA
                             AUDITOR'S REPORT ON INTERNAL CONTROLS
         Mrs.  Kathryn Kuhl-Inclan
         EPA Office  of Inspector General
         Audits  and  Investigations
         Southern  Division - Sutie 276
         1375  Peachtree Street,  N. E.
         Atlanta,  Georgia  30309

         We have examined the summary  of costs incurred,  accepted,  questioned  and/or
         set-aside of Tennessee  Department of Health and  Environmental Services
         (TDHES) Division of Solid Waste Management under Grant Number V004485-85-5
         for the period March 27,  1985 to June 30,  1987 and have issued our report
         thereon.  As a part of  our examination,  we made  a study and evaluation of
         TDHES system of internal  accounting control to the extent we considered
         necessary to evaluate the system as required by  generally accepted govern-
         ment  auditing standards.   The purpose of our study and evaluation was to
         determine the nature, timing, and extent of the  auditing procedures neces-
         sary  for  expressing an  opinion on the financial  statements.  Our study and
         evaluation  was more limited than would be  necessary to express an opinion
         on the  system of internal accounting control taken as a whole or on any
         of the  categories of controls identified below.

         Internal  accounting controls  surrounding the following significant classes
         of transaction activities were found in TDHES:

               1.   Disbursements
              2.   Payroll
              3.   Contractual Procurement
              4.   Cash Management  (Letter of Credit System)
              5.   Property and Equipment

         All of  the  above controls were studied and evaluated.

         TDHES is  responsible for  establishing and  maintaining a system of internal
         accounting  control.   In fulfilling this  responsibility, estimates and
         judgments by  management are required to  assess the expected benefits and re-
         lated costs  of control  procedures.  The  objectives of a system are to pro-
         vide the  governing board  with reasonable,  but not absolute, assurance that
         assets  are  safeguarded  against loss from unauthorized use or disposition,
         and that  transactions are executed in accordance with the governing board's
         authorization and recorded properly to permit the preparation of financial
         statements  in accordance  with generally  accepted accounting principles.
                                              -7-

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Ms. Kathryn Kuhl-Inclan
EPA Office of Inspector General
Page 2
March 22,  1988
                   AUDITOR'S REPORT ON INTERNAL CONTROLS
                                 (Continued)
Because of inherent  limitations  in any system of internal accounting con-
trol, errors or  irregularities may nevertheless occur and not be detected.
Also, projection of  any evaluation of the system to future periods is
subject to the risk  that procedures may become inadequate because of
changes in conditions or that the degree of compliance with the procedures
may deteriorate.

Our study and evaluation made for the limited purpose described in the first
paragraph would  not  necessarily  disclose all material weaknesses in the
system.  Accordingly, we do not  express an opinion on the system of internal
accounting control of TDHES taken as a whole or on any of the categories of
controls identified  above.  However, our study and evaluation disclosed con-
ditions that we believe to be material weaknesses.

Personnel

During our review of personnel costs, we found and observed the following:

     1.  TDHES requested reimbursements for overhead type payroll cost
         as a direct expense.  We believe that the cost incurred for
         the Director is an overhead cost pool item and should not
         have been claimed as a  direct expense.

     2.  TDHES claimed costs  for position that had not been approved by
         EPA.

     3.  Further, we noted that  salaries were claimed for individuals that
         had been transferred to another division which were not grant re-
         lated.

Recommendation

We recommend that:

     1.  All cost claimed for director be classified and included in the
         overhead cost pool.

     2.  All personnel positions be approved by EPA before these expendi-
         tures are claimed.

     3.  TDHES assures EPA that  all personnel cost be directly grant re-
         lated.
                                    -8-

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                                     STATE OF TENNESSEE
                        DEPARTMENT OF HEALTH AND ENVIRONMENT
                                    CORDELL HULL BUILDING
                                NASHVILLE. TENNESSEE 37219-5402
JAMES E. WORD
 COMMISSIONER
       June 8, 1988
       Ms. Kathryn M. Kuhl-Inclan
       United States Environnental Protection
         Agency
       Office of Inspector General
       Southern Division, Suite 276
       1375 Peachtree Street, N.E.
       Atlanta, Georgia  30309

       RE:  Draft Audit Report
            TN Cooperative Agreement
            V004485-85

       Dear Ms. Kuhl-Inclan:

       In response  to  your letter  and  findings regarding the  above  referenced  draft
       audit report, please  find  attached our  response.   During your  review,  please
       feel  free  to  call  Ms.  Donna  Dickens  at  (615)  741-3321  if  you have  any
       questions or if we can be of any assistance.
       Sincerely,
         "
        MES  E.  WORD
       Commissioner

       JEW/ A1018159
                                           -9-

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                              GRANTEE'S COMMENTS

           COMMENTS REGARDING COSTS INCURRED, ACCEPTED,  QUESTIONED
                               AND/OR SET-ASIDE
1.   Personneland Fringe Benefits

     Salaries  totalling  $94,345 and  fringe  benefits  amounting to  $19,681  have
     been questioned.   After  a review of these questioned costs by staff,  we
     concur that the federal grant was charged in error for  salaries amounting
     to  $56,440 and benefits  amounting to $12,782.   The  difference of  $37,905
     in  salaries and  $6,899 in benefits  represents  the personnel expenses  of
     the Chemist 2  identified  in  "Note 1, Item  D."   It is our contention  that
     although the  person  identified  and  charged  directly  to the grant
     (Mitchell) did not  spend  100% of her time  on this project, an equivalent
     amount of time vas spent by other lab personnel  to more  than  justify  this
     charge.  Documentation supporting this  contention is  available for review
     and discussion.

2.   Travel
     Of the $1,197 in travel costs that have been questioned,  $625  was  for  the
     director.  Since we have  concurred  that  the  director's salary should  not
     have been  charged  to  the  grant, we also concur that this expense  should
     not have been charged.     Of  the  remaining $572,  documentation for  $516
     has been located and  is available  for  review.   The  documentation  for  the
     remaining $56 has apparently been archived and not available.

     Professional Services
     Information  and  documentation supporting  the $125,625  in  charges  for
     laboratory services has been previously provided to your staff.   Since it
     is our contention that these are justifiable charges,  we shall await  your
     review of this information.

4.   Indirect Costs
     Indirect costs  totalling  $25,303 have been  questioned.   Of this  amount
     $18,012 was incurred during the fiscal year ending June  30,  1987  and were
     questioned because  they were  not  based on  the  final approved  indirect
     cost rate.   In absence of an  approved  rate  we were drawing down  on the
     basis of an  interim rate.   Now  that  we  have an  approved rate it  is our
     intention to make appropriate adjustments.

     The remaining  $7,291 that was  questioned  related to certain  Personnel,
     Travel-,  Professional  Services and  Other  Costs  that likewise  were
     questioned.   It is  our  intent  to make  appropriate adjustments to  this
     amount pending  a  final decision by the  EPA  to both the findings  of the
     auditors and our comments/rebuttals to those  findings.

5.   Other Costs
     Documentation  for  $726 of  other costs  questioned by  the  auditors  has
     apparently been  archived  and is not  available.   The remaining  $754  for

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                                 GRANTEE'S  COMMENTS

     rent costs  was inadvertently  charged to this  federal  grant  instead  of
     the previous grant.  In that the old grant has been closed,  we  would need
     to adjust the expenditure in the current year if so requested.   It is our
     contention however that this is a justifiable charge to  the  EPA.

Additional Allowable Costs

As a  re---.lt  of  the audit  process,  we discovered  that  allowable motor  pool
charges counting to $51,322 had not been charged to the  grant.   Consequently,
we respectfully  request that this  amount  be  used  to offset any  of the
previously identified unallowable costs.  Please find attached an analysis  of
these  charges.   Further documentation is available  upon request.
                                      -11-

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                                GRANTEE'S  COMMENTS
                        AUDITOR'S REPORT ON COMPLIANCE
Letter of Credit Drawdowns

During the past  several  months  the State of Tennessee has been implementing a
new statewide  accounting system^  Due  to  this,  we have sometimes experienced
delays  in  receiving actual  expenditure data  in order to make  our  scheduled
drawdowns.   Instead/we  have estimated  these  expenditures based on  reliable
information  with the  intent of  adjusting future  drawdowns  once the  actual
expenditures were received'.•>  The reports that  are now being generated by this
new accounting system are" providing us with  needed information in  a  timely
manner and  will, therefore,  enable  us  to  make  future draws based on  actual
expenditures.   We  shall also do a reconciliation  between past  drawdowns  and
actual needs in order to make appropriate adjustments.
                                      -12-

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                                GRANTEE'S COMMENTS
                    AUDITOR'S REPORT ON INTERNAL CONTROLS
Comments Regarding Internal Controls

Staff  of  the  Superfund  Program  are  reviewing positions  approved  by EPA  in
order  to  insure that  no federal  funds  are used for  unauthorized  positions.
Assurance is given that  in  the  future only those expenses that are  authorized
and approved shall be charged to  the grant.
A1028159
                                        -13-

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                  -14-

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        T33ESSEE DEPARTMENT OF HEALTH AND  ENVIRONMENTAL SERVICES
                     DIVISIOM OF SOLID WASTE MANAGEMENT
            FOR THE  PERIOD MARCH 27,  1985  THROUGH JUNE 30,  1987
               AUDITORS' RESPONSE TO THE  GRAT TIDE'S COMMENTS


Our  response below  is presented in  the same order as  the notes  in the
audit report on  pages 3, 4, and 5.

EXHIBIT A

:3ote 1 -  Personnel  and  Fringe Benefits

In Note 1 of the audit,  report  (page  4), we  questioned $94,345 of  personnel
costs and $19,681 of fringe benefits costs.  The grantee concurred with
$56,440 of  personnel and $12,782 of  fringe  benefits costs questioned.  The
grantee stated that the difference of $37,905  in salaries and $6,899  in
benefits  represented personnel  expenses of  a Chanist  2.   They concurred
that the  person  identified and  charged directly  to the grant did  not  spend
100% of her time to the project; however, the  grantee contends  that an
equivalent  amount of time was spent  by other lab personnel  to more than
justify the charges.  There was no position for  the Chemist 2 in  the
application nor  in  the  grant agreement/amendment.   Therefore, we  believe
the  total cost should remain questioned.

Mote 2 -Travel

We questioned  $1,197 in travel  costs because $625 was  charged for the
director  and the State  was unable to document  $572.   The grantee  concurred
with $625 being  questioned.  The Grantee  stated  that  the difference -r
$572 represents  $56 unsupported costs and $516 which  documents  had been
located to  support.  However, we were provided no additional documentation.
Therefore, we  reconmend that the total  cost remain questioned.

3NJote 3 -  Professional Services

We set-aside $125,625 in professional  charges  incurred for laboratory
services.  These costs  were set-aside because  the grantee was unable  to
provide the basis for the time  units used to determine the amount to bill
to the agreement.   The  grantee  stated that  time  and motion studies had been
performed and  that  a report resulted from these  studies.   This  grantee
stated that th^ would  submit a copy of this report to us prior to the
rqport date.   The grantee subsequently submitted seme data (See Appendix
A); however, they stated that the original  documentation was "lost or
destroyed".  Since  we were unable to make a determination of the  basis of
the work  tiine units used, we have set them  aside pending a  technical  review
by the Region.
                                   -15-

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        TENNESSEE DEPARTf-E-.T OF HEALTH AND ENVIRONMENTAL SERVICES
                    DIVISION OF SOLID IvASTE MANAGEMENT
           FOR 'THE  PERIOD MARCH 27,  1985  THROUGH  JUNE 30,  1987
               AUDITORS' RESPONSE TO 'THE:  GRANTEE'S COMMENTS
Note 4 - Indirect Charges

In  the audit report, we questioned  $25,303  ($7,291  -  in  relation  to Xotes
1,  2, 3, and 5 and  $18,012  - unapproved rates)  in indirect costs.   We
reviewed the grantee's cements on  Page 10.   Since  we recommend that the
costs in Notes 1, 2, 3, and 5 remain questioned, we believe  that  the
$7,291 of indirect  costs relating to these costs should  also remain
questioned.

A '-otal of $18,012 was questioned because there was no approved indirect
cost rate.  Subsequently, the grantee stated  that the indirect cost rate
plan has been approved.  However, the grantee did not provide us with a
final approved indirect cost rate plan.  Therefore, we are recommending
that the $18,012 remains questioned until review by EPA.

Note 5 - Others

We questioned $1,480 because $726 was undocumented  and $754  rent was for
the previous grant period.  The grantee stated  that the  $726 was  apparently
in archived and is not available for review and the $754 for rent was
inadvertently charged to this grant.  Since the grantee was  unable  to
document the $726 and $754  for rent was inadvertently charged to  this
grant, we recoranend that the cost remain questioned.

Additional Allowable Costs

The grantee stated  that they discovered additional  allowable motor  pool
charges amounting to $51,322 that had not been  charged to the grant.
However, the grantee did not provide us with  documentation to substantiate
the charges.  We recommend  that this cost not be included until it  has
been reviewed.

-------
         TENNESSEE DEPARTMENT OF HEALTH AND ENVIRONMENTAL SERVICES
                    DIVISION OF SOLID WASTE  MANAGEMENT
               FOR THE  PERIOD  MARCH  27,  1985  TO  JUNE  30,  1987
                AUDITORS'  RESPONSE TO THE  GRANTEE'S COMMENTS
                      AUDITORS'  RESPONSE  ON COMPLIANCE
Letter o£ Credit Drawdown

Our review disclosed chat drawdowns on the letter of credit are based on esti-
mating the expenditures in lieu of actual costs in  -rred.

The grantee stated that a new accounting system has been implemented which
should correct this deficiency of drawdowns on the letter of credit in the
future.
                                    -17-

-------
                                                               Aooenclix A
TENNESSEE DEPARTMENT OF HEALTH AND ENVIRONMENT

OFFICE CORRESPONDENCE
DATE:

TO:

FROM:

SUBJECT:
March 2, 1988

Donna Dickens

Don Brown

Recent EPA Audit of Federal Superfund
            As you know, at  the  exit  conference for the  recent  EPA  sponsored  audit
            of the Federal  Superfund  Program,  documentation for the Work  Time Unit
            (WTU)  values  used  in  billing  the  cost of   laboratory  testing  to  the
            Superfund  Program  was  requested.    In  requesting this  information,  the
            auditors stated  that we would  probably  need  to  furnish this information
            lirectly to EPA  rather than  to the  audit firm in Memphis.   The  purpose
            of this memorandum is to assist you is responding to that request.

            Attached you will  find  excerpts from the Work Time  Unit  Catalogue from
            CDC  (Center for Disease  Control)   dated  January,  1986.    While  this
            catalogue,  and  its predecessors, deals  primarily with  microbiological
            testing, portions  of  it deal  with  environmental testing which  are  the
            excerpts  attached.    The  work time  unit   values  in  this  catalogue
            represent  the basis for many  of the work time unit  values  used  by this
            laboratory  in   assigning   time  values   to  tests  performed.     This
            information  is  then supplied   to your  office periodically  for  use  in
            allocating  the  costs  of operating  the  Environmental Laboratory to  the
            various Environmental Programs which we support.

            For those  tests  performed  by this  laboratory which  are  not  included  in
            the CDC  catalogue, average  times  were  determined  by best  estimation,
            usually by the  chemists performing  the  tests.   This  process  initially
            occurred under  the oversight  of  a  select  coraittee,  but  the original
            docuaentation has  since been lost  or destroyed.   In addition,  we have
            informally  attempted  to   keep the  work  time   unit values   for  tests
            updated  through  the  years  to  account  for  changes  in  technology.
            Attached  also  is   a  current   listing  of   the   work time  unit   values
            associated with all of our environmental testing.

            It should  be  pointed  out  that  we are,  at  this  time, in the midst  of  a
            formal time study  to determine  up-to-date work  time  unit  values  for all
            tests  performed  by our Environmental  Laboratory.   This time study  is
            being  conducted   in   conformance   with  the  CDC   guideline   entitled
            "Analytical Methods in Laboratory Administration, Part I  Measurement  of
            Productivity,  Time  Studies"  (copy  attached)   and  is  being  done  in
            cooperation with the Association of  State and Territorial  Public Health
            Laboratory  Directors  and  with  CDC.   This  information,  when  complete,
            will be maintained as documentation for any future audits.
            DB/B0028060

-------
                   WORK TIME  UNITS
                        CATALOGUE

                          JANUARY 1986
                  A Collaboration of the Association
                 of State and Territorial Public Health
                    Laboratory Directors and the
                     Centers for Disease Control
Management and Information Systems Committee.

Henry Bradford, Ph.D., Chairman  (Louisiana)
Roger H. Carlson, Ph.D. (Kansas)
Harry J. Colvin, Ph.D. (Alaska)
Loris W. Hughes, Ph.D. (New Mexico)
Arthur F. DiSalvo, M.D. (So. Carolina)
Michael W. Kimberly, Ph D. (Tennessee)
George R. Anderson, D.V.M (Michigan)
G. Wolfgang Fuhs, Dr. sci. nat. (California)
Mahadeo P. Verma, Ph.D. (Delav;are)
David T. Pegg, Advisor & Catalogue Editor (C.D.C.)
         U. S. DEPARTMENT OF HEALTH AND HUMAN SERVICES
                      Public Health Service
                    Centers lor Disease Control
                    Laboratory Program Office
         Division of Management Development and Consultation
                     AUanta, Georgia 30333

-------
                                  INTRODUCTION

State and territorial public health laboratories analyze approximately
22.5 million specimens a year, performing an estimated 247 million
procedures.  The Association of State and Territorial Public Health Laboratory
Directors (ASTPHLD) reports that these laboratories employ approximately 5,600
persons, and spend over $200 million annually.  In addition, approximately
250 city, county, and city-county public health laboratories contribute
significantly to the identification and reporting of disease entities
important to public health in the United States.

With demands for laboratory services constantly increasing and resources
becoming more difficult to secure, public health laboratories need effective
management tools that will:  (1) adequately measure workloads, (2) properly
affix costs per unit of work, (3) relate effectiveness and effort in the
various sections of the laboratories, and (4) accumulate data for use in
presenting and defending their efforts to their administrative superiors,
their own staffs, Legislative committees, and their client groups.

In Hay 1970, a Task Force was formed to study this problem and to develop 8
methodology by which public health laboratory directors  could quantitatively
equate resource input to reported output.  The Task Force recognized that each
public health laboratory employed valuable and scarce resources, such as
personnel, money, equipment, and facilities (input), to derive useful
laboratory data (output).   The common need was for a management tool that
would quantitatively relate cost and workload efficiency to the use of
resources and the production of test results.  The results of this Task Force
effort. Diagnostic Workload Measurement:  A Relative Value Structure for
Public Health Laboratories, were published in September 1973.

In April 1977, a second Task Force was formed to evaluate the workload
measurement system developed in 1973.  Definitions, skill factors, and times
by batch size were checked, and, if necessary, reevaluated.  In addition to
the five state laboratories represented by Task Force members, 23 other state
public health laboratories were asked either to contribute additional data or
to check existing data.  This Task Force made a major change from the concepts
of the 1973 publication in which time, skill factor, and frequency were
combined to form "relative values."  They proposed that time alone should be
used to measure work, hence the term "work time unit."  The results of the
Task Force effort, Work Time Units:   A Diagnostic Workload Measurement
Structure for Public Health Laboratories, were published In April, 1979.
Approximately 600 procedures, normally performed in a public health
laboratory, were listed in this publication.

The extant Work Time Units Catalogue maintains the time unit concept developed
in the 1979 publication and follows the same format with the addition of a
date for the time standard and a code number for each test or procedure.  The
Catalogue has been put on the computer and every effort will be made to
provide current descriptions and standards to meet the dynamic needs of the
Catalogue holder through the periodic issuance of Catalogue updates, training
in Catalogue use, coordinated standard determination, and electronic data
exchange.

-------
In this Catalogue, tests and procedures are grouped within an alphabetical
listing of functional categories and subcategories In the format of Code
Number/Date of Standard, Procedure Name, Skill Factor, Time by Batch Size, and
Definition.  The derivation of the procedure or test names depends, for the
most part, on the category under which they are listed.   There is a wide
variety of scientific disciplines shown in this Catalogue, each with its own
methodology and manner of description.  Some procedure names are derived from
the name or title of the bench work, others according to the analyte,  and
still others according to the substance or medium being  used.   This lack of
consistency is regretted by the editors but perhaps forgivable by the  user.
We hope the consistency will improve as the newer disciplines become better
defined.

The definitions are simply short descriptions of the work being done.   They
are not meant as protocols for the procedure.  It is hoped that each
definition is clear enough to distinguish each procedure from the others.

Five levels are used to span-the skill factor range.   The level shown  by each
procedure is the skill factor of the person the Task Force felt would  probably
perform that procedure in a public health laboratory. The five levels and the
criteria for choosing or assigning one of the levels are shown below.   If a
procedure were being considered for a skill factor level, it might be  derived
in two ways.  First, if it were decided that the procedure was not routine and
that its protocol required much decision, then the level D would be chosen
(criterion 1).  Second, if it were decided that the procedure was performed
and interpreted by someone with a master's degree or the equivalent in
experience or training, then a level D would be chosen (criterion 2).   The
utilization of these skill factors will be developed further under "Numbers
and Skill Levels of Personnel."

                               SKILL FACTOR
LEVEL
            CRITERION 1
CRITERION 2
            Extremely routine, no
            decision
                                                 High school degree
                                                 or equivalent
            Routine, some
            decision
                                                 One or two years of  college
                                                 or specialized training
            Nonroutlne , some
            decision
                                                 Bachelor's degree and/or
                                                 license or certification
            Nonroutine, much
            decision
                                                 Master's degree and/or
                                                 license or certification
            All decision
                                                 Doctor's degree and/or
                                                 license or certification

-------
The standard time, or Work Time Unit (WTU),  for each test or procedure is
shown by normal batch size.  Recognizing that efficiencies of production are
operative, the WTU's per specimen generally decrease as batch size increases.
An "X" has been placed where a time standard is not available for a particular
batch size.  An "*" following a time shows it is different from the previous
publication or update.  The "*" will be dropped and the Date of Standard will
be updated when this new time is accepted as the standard.  When "*'s" follow
all the times for a procedure, they show that it is a newly added procedure
for which standards have not been accepted.   Likewise, they will be dropped
and the Date of Standard updated when the times are accepted as standards.

The Work Time Units shown in this Catalogue  are intended to measure only the
analytical time to accomplish the tests and  procedures as described in the
definitions.  They do not normally include the non-analytical time required
for (1) preparing standard solutions and reagents,  (2) pouring and sterilizing
media for microbiological studies, (3)  collecting specimens, (4) logging in
and labeling specimens, (5) instrument  operating or performing a step in a
procedure being automatically processed (incubating time, etc.) while the
laboratorian is employed on other duties, and (6) clerical work involved in
reporting results after they are first  recorded.

This does not mean that the non-analytical times will be ignored.  Indeed,
they represent a significant amount of  each laboratory's work.  The treatment
of non-analytical time depends on the organizational level of the unit In
which the work occurs and is developed  further under "Test Costs."

To make this document easier to use, certain tests (for example, direct
fluorescent antibody (FA) staining] have been listed under more than one
technical heading.  Many quality control, standard, repeat, and duplicate
tests should be considered additional procedures and assigned the same WTU as
the procedures performed on the specimen.  If a definition for a procedure'
states that quality control, standard,  repeat, and duplicate tests have been
included in the WTU, these tests should not be counted a second time.

Whether a procedure is automated or manual is of utmost importance.  This
distinction is shown either in the definition or by listing the procedure
under a heading indicating that it is automated.

Since their inception, Work Time Units  have assisted many public health
laboratories, as well as private and hospital laboratories, to develop the
quantitative data necessary to accurately estimate test cost, calculate
productivity, support personnel needs,  and forecast budget, personnel, and
space requirements.

Four examples illustrating the use of Work Tim<> Units follow.  The first
illustrates their use in estimating test cost using standard cost accounting
techniques; the second, In calculating  workload efficiency; the third, in
estimating the numbers and skill levels of personnel needed; and the fourth,
in forecasting workload.

-------
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         ANALYTICAL METHODS

   IN LABORATORY ADMINISTRATION
               PART I

    MEASUREMENT  OF PRODUCTIVITY
             TIME  STUDIES
   by:  Cecil S.  R.  Duncan, M.P.H.
        Laboratory Management Consultation Office
        Bureau of Laboratories
U.S. DEPARTMENT OF HEALTH. EDUCATION. AND VYELf ARE
           PUBLIC HEALTH SERVICE
         CENTE" FOR DISEASE CONTROL
          ATLANTA, GEORGIA 303)1

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                                  TIME STUDIES

     This session has two objectives:  (1) to show  the difficulty  in making
accurate time studies; and (2) to describe basic procedures for those who must
determine a time unit for a test not  Included in established systems*>2,3 or
for a test which listed time units are erroneous due to unusual conditions in
the work setting.  The intent is not  to encourage indiscriminate or unnecessary
time studies because:  (1) the process is tirae-consuraing, (2) it is more diffi-
cult than it appears, (3) individual  time standards make comparisons or dis-
cussions difficult if not impossible, and (4) human relations must be carefully
attended to; otherwise fear or dissatisfaction will occur among the staff.

     One author defines the time study as ".... a procedure used to measure
the time required by a qualified operator working at the normal performance
level to perform a given task in accordance with a specified method."^

     The methodology for time studies dates from about the beginning of this
century.  Frederick Taylor,^ known as "the father of scientific management"
is given credit for the development.  Time studies are part of a larger field
of Industrial engineering which includes the study of methods and motion.
However, this session will concentrate only on the time element.

Time studies consist of the following five basic activities:^

1.  Recording the method.  Each step  of the procedure is outlined  in detail.
    Each step roust have identifiable  beginning and ending points.  The sum of
    the steps must equal the total cycle of the process.  (Nothing should be
    left out.)

2.  Timing the steps.  Each step is  timed by an observer with a stopwatch.
    Multiple timing is necessary for  accuracy.

3.  Rating the effort.  While timing  the steps, the effort level of the worker
    is assessed, to indicate the relationship of the work being timed with the
    work effort judged by the observer as "normal."  This effort level may be
    judged on a step basis or on the  basis of the entire procedure. Rating is
    normally expressed as percent.

4.  Calculating normal time.  Normal  time for each repetitive observation of
    a step is calculated as the product of the observed time and the rated
    effort.  The normal time for the  entire procedure ia then the  sum of  the
    normal times for the steps.  If  the effort was rated only on the entire
    procedure, then the elapsed step  times are added and the sum is multiplied
    by the rated effort to obtain normal time for the entire procedure.

5.  Establishing standard time.  Allowances may be made to normal  time due to
    unavoidable delays or other legitimate causes not under the control of the
    worker.  The standard time is established by adjusting (usually increasing)
    the normal time or the average normal time from several observations to
    accommodate the allowances.  Allowances are usually expressed  as percent.

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     The reader should be aware  tliat where  steps  can  be  broken  down  to  minute
motions, such ae hand motions of grasping an object,  lifting, transporting,  and
releasing, tables of predetermined  standard times  exist  for  such movements.   It
Is beyond the scope here, however,  to deal  with time  studies  in that  detail.
Also, predetermined standard times  do not exist for all  motions,  and  other
elements such as delays would have  to be timed by  stopwatch anyway.

     Although it would seem that a  stopwatch time  study  is completely objective
and Irrefutable, in fact there are  large subjective elements  with which the
observer must deal.  One must realize that  "work"  is  related  to the energy
required to perform the task.  The  relationship can be expressed  in equation
form as:

                         WORK - EFFORT X TIME

Therefore the work involved in performing a laboratory procedure  is the effort
multiplied by the time required, and both must be  considered  by the observer.
It should be obvious that when one  is performing a time  study properly,  it Is
work, rather than time alone, which Is being measured.   The work  content of
a task Is represented by normal time, which is the product of effort  and time
required.  The calculated normal time is therefore the time  required  to perform
the complete procedure by a qualified person working  at  a normal  level  of
effort.

     If all workers were equally qualified  and performed always at an optimal
level of effort, then rating of effort would be unnecessary.  Workers vary,
however, in skill level, from day-to-day, within-day, and in  other ways.   The
fact that the worker is being observed and  timed can  have an  effect on  effort.
Skill in the rating of effort requires training and experience; in the  meantime
multiple measurements of different  workers  at different  times of  day  can
provide some compensation for a beginner's  lack of skill.

     To overcome difficulties in time measurement, one must  realize that the
work system is dynamic, changing or varying over a period of  tine.  Standard
times which are used to forecast or evaluate future performance must  include
analysis of variation and change and their  causes.  Time study  is therefore
essentially a sampling procedure.   This fact often leads to  problems  when  the
period of time studies is too short or for  other  reasons is  not representative
of normal conditions.'

     Sampling is a feature of the CAP1 and  the Canadian^ system of work units.
The public health-' system suffers,  in its first edition, from inadequate
sampling, particularly in the rare  and esoteric tests performed by few  labora-
tories.  It is assumed that progress will enable the  public health system  to
improve accuracy in future editions just as did the other systems which had  the
advantage of a head start.

     The CAP system achieves sampling by inviting  a minimum  of  10 laboratories
to engage in a time study on a single procedure as it IB done by  a single
methodology.8  According to  the  package of  instructions  provided, each  parti-
cipant is requested to time  the  steps "at least three or four times"  using
          technologists and on different days.  There is no  provision for

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racing of effort in the instructions.  The  result  is  a  set  of  standard  times
which, although lacking in rating of effort  by skilled  observers,  consists  of
a sample size of at least 30 and possibly 40 or more  observations  for each
procedure listed.  When invited to participate in  such  a study,  It  is important
to follow the instructions exactly, and  to  disregard  conflicting or additional
instructions from others.  Information about work  measurement  is provided by
the College of American Pathologists to  those who  participate  in the develop-
ment of work units listed in their publication. ^   If  questions arise, the
instructional materials usually give a name  and telephone number to contact.
       >
     It is hoped that, by this time, the reader understands  the problems in
making a time study and the advantages of using appropriate  established  lists
of standard times, or time units, whenever  possible.  In light of  the fact,
however, that no list is 100 percent complete, the basic steps in  making a
time study will be outlined.  Readers are encouraged  to use  the industrial  or
systems engineer in their hospital or a  consulting industrial  engineer if
possible, because those professionals are trained  in  the required  skills.   In
such case, knowledge of the procedures outlined here  will aid  in understanding
of the process and may reduce the time required for the study.  If  professional
skills are not available, the basic process  described here  may not  be enough,
and one may wish to consult additional references. »^

     Also, ignoring the human relations  factor In  time  studies can  lead  toward
serious labor problems.  Workers must understand and  agree with the objectives
of the study.  Fear of punitive action can  lead toward  activity which appears
Irrational to management but perfectly rational to the  workers.  Good manage-
ment with a participative leadership style  can lay the  groundwork  to allay
fears.  This article does not cover the  human relations aspect of  time studies,
but the reader is cautioned that attention  must be given to  that factor  if  the
outcome of the time study is to be successful.

     The basic tools required are a good stopwatch, a clipboard  (preferably one
which has an elbow cut-out and stopwatch holder) and  a  form  for recording data.
Although a good time study observer can  obtain adequate results with a
wristwatch and using the back of an old  envelope for  recording data, proper
tools are relatively inexpensive.

     There are several kinds of stopwatches.  Some are  mechanical  (resembling
a pocketwatch) and others are electronic.   The electronic watches  are becoming
cheaper to buy but require battery replacement periodically. The hands on  the
mechanical watch are equivalent to the decimal counters on  the electronic
watch.  Reference will be made to the  "hands" of the  watch,  which  should be
translated to "decimal counter" for the  electronic watches.

     There are three further classifications of stopwatches  which  are
important.  Type  L is the decimal-minute stopwatch.   This watch records  time
In minutes and hundredths of a minute  (not  seconds).  Therefore, this watch
provides data to two decimal places.   The maximum  continuous time  for recording
by most of these watches is 30 minutes.  Type 2 la the  decimal-hour stopwatch
which records time in 0.0001 hour increments, or four decimal  places.  Type 3
Is the split-hand stopwatch which, in  the mechanical  version,  has  two  large
hands.  The observer can start both hands,  atop both, and return both  to zero

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simultaneously.   In addition,  the operator can  stop  one  hand  while  allowing
the other to continue, and later can cause the  stopped hand to  "catch  up"  and
continue with  the first hand.  There are also variations  of type  I  and type 3
watches which  record time in minutes, seconds,  and hundredths of  a  second.
These variations  are found in  some  brands of electronic  stopwatches.

     There is more than one type of watch because there  is more than one way
to time work.  One way is called the "snap-back" method,  where  at the  end  of
timing the first  step of the procedure the watch hand is  returned to zero  and
the ttme is restarted for the  second step.  There are three disadvantages  to
the "snap-back" method.  One is that time is lost while  returning the  hands to
zero and restarting the watch.  A second disadvantage may be  more Important in
timing laboratory procedures:  If the time is restarted  at each step,  delays
and interruptions are not noted in  the data, and later analysis may not  Include
such Information, which is useful in establishing allowances.  The  third
disadvantage is that the sequence of the data Is lost, and if a step is  done
out of sequence,  then it is difficult to note.

     Either of the first two types  of watches is suitable for snap-back  timing,
but the first, the decimal-minute stopwatch Is  probably  better  for  timing
laboratory work with the snap-back  method because fewer  errors  will be made In
recording 2-place decimal data than In recording 4-place  decimal  data  or data
which is read  in  terms of minutes,  seconds, and hundredths of a second.

     A better way to time work Is called the "continuous" method.   Here, the
watch Is started  at the beginning of step one of the procedure  and  continues
throughout the entire cycle of the  procedure.   Step endings and delays are
noted as they occur.  The split-hand watch was  designed  for this  method  and
provides a way of stopping one hand to read the time without  interrupting  the
continuation of the other hand.  Practice in using the stopwatch  and operating
its switches will aid the observer  so that full attention can be  given to  the
work being timed.

     Once the  tools are assembled and practicing is complete, the next step is
to study the procedure to be timed.  We will assume here  that no  improvements
in the procedure  need to be done because we are concentrating only  on  the  tim-
ing of the work.  It is still  Important, however, to check that the procedure
to be tinted is the desired methodology.  The worker may  have  developed some
unauthorized short-cuts of which management is  unaware.

     The procedure must be broken down into logical steps, each with
Identifiable beginning and ending points.  The  observer  must  be able to
recognize the  beginning and ending  points to record data.

     Steps which  do not require worker involvement should not be  timed because
the worker can be doing something else.  In cases where  that  time is very
short, the observer will have  to judge whether  the worker can or  cannot  perform
useful work in the interval.   When  a specimen is in the  centrifuge  for five
minutes or incubating overnight, there la no question that other  work  can  be
performed.  However, the steps of placing material In the centrifuge and
turning it on as  well as removing the material  from the  centrifuge  should  be
included.

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     The next step is to select  the worker  to  be  timed.   It  is best to select
a person who Is trained and produces at a normal  effort  level.   It  is  also
helpful to select a worker who is  agreeable  to  the  process of  being timed.
A suspicious worker may try to bias the result.   Even after  selection  of  an
agreeable worker, it Is important  to describe  the objectives and  plan  to  the
point that the worker understands  what is going on  and why.

     The next step, just prior to  actual timing,  is  to record  certain  data
which will be useful later:  name  of observer, name  of worker,  time of  day,
room, name of procedure, unit of count, date, equipment  used,  availability of
material, batch size, and special  conditions such as the centrifuge being
locate^ in another room.  It is also necessary to note whether  the  specimen is
an unknown, standard, quality control, repeat, or blank.  Sometimes a  sketch
of the layout of the work station  is useful  to show  any  unusual  locations of
equipment or materials.   Also,- if  the beginning or  ending of a  step in  the
procedure is obscure, a note stating what constitutes the beginning or  ending
point Is helpful.  The data should be complete enough so that another observer
would time exactly the same events under conditions  as similar  as possible.
Also, the recorded data can be useful at a later  time because when  conditions
change, such as room layout, the time o£ the procedure cycle will change.

     Figure 1 shows a suggested format for the time  study.  Other forms are
shown In the references.^»"  Figure 1 is designed for observation of a  single
worker performing a single procedure.  Figure 2 is  provided  to  summarize
multiple observations.  When participating in studies for the CAP or others,  a
format is provided by the sponsor.

     Figure 1 provides space to record pertinent  data as well as  information
about the steps being timed and the timing results.  The column headed  Begin/
End Time has a slash which enables recording the  beginning time above  the slash
and the ending time below the slash.  This format is particularly useful  for
snap-back timing.  In continuous timing, however, the end of one  step  is  the
beginning of the next unless extended interruption occurs.  Therefore,  if  one
is using continuous timing, it is  not necessary to  record the beginning time  of
a step unless an interruption for a non-involved  time (such as  incubation)  has
occurred between timed steps or when a step  Is performed out of sequence.

     It Is necessary to record the number of units  processed (No. Proc.)  at
each step*  As an example, a single sample may be processed  through most  steps
but when centrifuging is done, a batch of six specimens will be centrlfuged at
once.  Although the time involved  while the  centrifuge is spinning  Is not
included (because It is non-involved time for the worker), the  steps of placing
the specimens in the centrifuge and taking them out  are  Included.   In  that
case, the elapsed time for placing all the specimens (e.g. 6) In  the centrifuge
la divided by the number of specimens (e.g.  6) processed at  that  step  to  obtain
the elapsed time for one specimen  at that step.   Also, there are elements  in
procedures which are performed only once per day  or  only once for every "x"
number of specimens.  Examples of  such elements include equipment calibration
and various quality control checks which do  not constitute whole  procedures.
In such case, these intermittent elements should  be  included in the  steps  and
timed.  The elapsed time for such  elements which  should be a part of each
normal time is found by dividing the average number of specimens normally

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processed between  such  Intermittent  elements  Into  the  measured time for the
element.  As an example,  If an  instrument  must  be  calibrated  at  the beginning
of a shift, and on an average shift  100  specimens  are  processed,  then the
measured time for  calibration can  be  divided  by 100  and  added to  the elapsed
time for one specimen.   It  is inappropriate,  however,  to treat standards,
repeats, and other such  elements  In  this manner if they  receive whole
procedures, because  they  are normally  counted and  credited  to workload  in
addition to the unknown  specimens.

     Although specimens  are often  processed through  a  given step  in a procedure
aa a batch, some procedures in  some  laboratories are normally applied to  large
batches of specimens.   For  a procedure to  be  "batched,"  a group of  specimens is
processed in parallel (simultaneously) through  each  step of the procedure.   For
example, all specimens  receive  step  I  before any receive step 2.  The fact  that
intermediate or final results'are  read individually  does not  change the  fact
that a batch is processed.  However,  it  is not  a batch if one specimen  is given
step 1 while another is  in a waiting period (e.g., shaking or centrifuging)  at
a later step.

     Batched specimens  may  be timed  as a group,  and  later the elapsed time  for
one specimen can be calculated  by  dividing the  batch time by  the  number of
specimens in the batch.

     Consideration of batch times  is importa-nt  in  a  high-volume laboratory
because economy of scale can affect  Individual  specimen  time.  The  observer
should not time a batch, however,  unless the procedure is normally  done on
batches of specimens.  In such  case, a batch size  as close to normal as
possible should be selected for timing.

     Figure 2 is provided to summarize the elapsed times recorded for multiple
observations and timed by the same observer.  When multiple observations  are
timed under these conditions, the  allowance and standard time calculations  are
not made on Figure 1.  Rating and  normal time are  calculated  on Figure  1,
however, because different workers and different times of day may be used in
the multiple observations.  Separate copies of  Figure  1  are used  for each
observation.  In such case, each observation results in  a rating  and a  normal
time on Figure 1; Figure 2 is then used  to calculate the average  normal  time
for all observations and  to provide  for allowance  to obtain standard time.

     Rating is a subjective and difficult step.  Figure  1 provides  scales from
"1" to "10" for the observer to rate the worker on both  skill and effort.   If
preferred, one can replace this continuous scale with  a  discrete  scale of poor-
fair-average-good-excellent-excessive.  Regardless of  the scale used, the obser-
ver must Judge the worker in terras of his or her concept of what  is "normal"
skill and effort.  It helps to  remember what has been  said before,  that the
time study Is ".... a procedure used to measure the  time required by a
qualified operator working at the  norma1 performance level to perform a given
task in accordance with a specified method."''   (emphasis added).

     The rating is a method by  which the observer  can  increase or decrease  the
observed (elapsed) time as a result of judgment about  the skill and effort of
Che worker.  The amount of  the  rating  is intended  to increase or  decrease the

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time such that  It reflects what a qualified operator  would  do  when performing
normally.  Lf,  for example, the observer  feels  that the  worker is  working 10
percent slower  than whatever the observer  Judged  to be  "normal",  then the
elapsed time must be decreased by 10 percent.   In  that case, the  rating  percent
would be - 10%.  The elapsed time would  thereby be multiplied  by  0.90 to obtain
normal time.  If the worker was 10 percent faster  than normal,  the  rating
percent would be +10% and the elapsed time would  be multiplied by  1.10  (one
whole elapsed time plus 10 percent) to obtain normal  time.  This  process of
rating elapsed  time to obtain normal time  is also  called  "leveling."

     The need for rating is particularly  significant  when the  sample  is
smaller.  Large sampling, as done by the  CAP, reduces the requirement for
rating because  the data includes many laboratories and many workers.

     Once normal time is calculated, an additional adjustment  is  needed  to
obtain a standard time.  This adjustment,  which is similar  to  the  rating, or
leveling, process is called "allowance."   Unavoidable delays,  which are  delays
not under the control of the worker, occur.  These must be  considered In
setting a fair  standard time.  Unavoidable delays  include supervisory interrup-
tions; waiting  for, or going to get, material; equipment adjustment or repair;
or anything else that, not by the worker's choice, prevents him or  her from
producing.  It  is important that all delays be included in  the  timing, and
analysis of the results in which the time  for unavoidable delays  is noted will
aid in establishing allowances.  Of course, delays on the time study  sheet
should be classified as avoidable or unavoidable  to aid in  this analysis.
Delays will sometimes be missed by the observer when  using  snap-back  timing;
whereas continuous timing establishes a complete  record of  all delays.

     The percentage for allowance is treated in the same way as the percentage
for rating of skill and effort.  The allowance  is  simply another  adjustment
aimed at establishing the end product, which is standard time.  Normally, the
allowance adds  time.  If it is judged that the allowance is 10% of  the normal
time, then the normal time is multiplied  by 1.10  (one whole normal  time  plus  10
percent).

     Figure 3 is an illustration of the use of continuous timing  of a
urinalysis.   The format Figure 3, sheet  1  is the  same as that  given in Figure
1.  Figure 3, sheet 2 ie also a duplicate  of Figure 1 because  the  procedure
required more steps than could be shown on one form.  Neither  the  procedural
steps nor the times are recommendations or factual.   The steps were chosen to
Illustrate elements and the times were chosen as  numbers easy  to  grasp.

     It Is assumed that the worker lias been selected  and oriented  prior  to this
point.  The information at the right of the form  is filled  in  (to  the extent
possible prior  to the observation).  Step  numbers  and step  descriptions  also
are recorded and checked to see that the  beginning and ending  of each step is
apparent to the observer.  The illustration is  based  on  the use of  continuous
timing with a type 3 stopwatch calibrated  in minutes  and hundredths of a
minute.

     At 8:05 a.m., the stopwatch is set to "0" and timing begins.   The observer
notes the type  of specimen (unknown, in this case) and that six specimens are

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handled simultaneously at this step.  The end point,  when  the  specimen Is  on
the bench, materials arranged, and John Doe has picked up  the  first  request
form, Is noted on the stopwatch as 1.20 minutes.  The beginning  time Is
understood to be "0" and Is therefore not recorded.  Elapsed j: line  Is not
calculated while timing by the continuoustiming methodbecause  It will occupy
the observer, causing missed data.  Note also that six specimens were  processed
at this step, an Important point used later when calculating elapsed time.

     With continuous timing, the end time of the first step is automatically
the beginning time of the second step.  If a delay occurs  between  steps, It  is
credited to one of the adjacent steps.  The second step is the same  unknown
and, at the end of this step, the watch indicates "1.45" minuLes.  The  end time
could be recorded as "1.45", but normally the whole minutes are  left out until
the next higher minute arrive? (See step 6).

     The timing continues as described through step 7, In which  the  worker
is not involved while the centrifuge Is spinning (In  this example  for  five
minutes).   The observer could have reset the watch to "0" and  started  a new
sequence of time for step 9.  In this case, the non-involved time was  rela-
tively short and the watch was left running.  However, a lengthy non-Involved
step, such as incubation, could exceed the capacity of the watch.  In such  case,
restarting at "0" for the next step would be required.

     At step 12, a delay occurred.  John Doe, the worker, discovered he did  not
have a slide available for the microscopic examination.  At the  beginning of
the step (time 10.45) he had to reach Into a drawer, grasp a box of  slides,
remove them, and open the sealed box.  Ordinarily, the box would have  been
ready at the end of Step 1, so this time is a delay.  In some  opinions, this  is
an avoidable delay, but the fact Is that.lt does happen, regardless  of  the care
taken by the worker, and is therefore classified as an unavoidable delay.
Workers must be judged as human beings when dealing with delays  which  are  used
later to establish allowances.

     The delay began at the beginning of the step (time:   10.45  minutes into
the cycle) and continued until 10.80 minutes.  The delay, which  was  not a
planned step and is therefore not accommodated in the center of  the  form,  is
recorded at the bottom right-hand corner of the sheet.  Again, the elapsed time
is not calculated until later.

     Once the delay was over (at 10.80 minutes), it required until 12.30
minutes to complete step 12.  Later, when calculating elapsed  time,  the
observer can calculate that 1.85 minutes was required for  step 12  with the
delay (12.30 - 10.45) and 0.35 minutes was required for the delay  (10.80 -
10.45) therefore the elapsed time was 1.50 minutes for step 12.

     Another delay  (1.00 minute) occurred at step 15; however, this  was an
avoidable delay because the worker stopped to chat with a  friend.  Although  the
delay is recorded, it is not considered when, at a later date, the observer
estimates allowances.  Sometimes it is difficult to Judge  whether  a  delay  is
avoidable or not, and continuous timing has the advantage  that all delays  are
recorded; judgment can be applied later.  With snap-back timing,  judgment  may
be made on the spot and later regretted, but data may be lost  by that  time.

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     At the end of the steps, step  1 is  recorded  (as  step  IA)  again.   The
purpose is to record any unavoidable delays between cycles  which  must  be
realistically added to the last step of  the cycle.  In  the  case of  this
example, there was no such delay.

     Once the data is recorded, elaspsed time  is  calculated  for each step  by
subtracting the ending time from the beginning time and subtracting out delays.
In step 1, six specimens were processed  simultaneously; since  the unit for
count is specimen, the elapsed time (1.20 minutes) for  the  six specimens is
divided by 6 to obtain the elapsed  time  (0.20) for one  specimen.  The  same type
of division is made at steps 7, 8, and 9.  In  the case  of step 8  (centrifug-
Ing), there is five minutes of non-involved time; therefore  no elapsed time is
recorded.

     The time for steps 12 and 15 are the ending  times  minus the  beginning
times minus the elapsed times for the delays.  Total  elapsed time is the sum
of the individual step times, and does not include any  delays or  non-involved
time.

     The observer must next estimate a fair rating based on  the workers skill
and effort.   John Doe's skill was Judged average  for  this particular procedure,
but due to the fact that he starts work  at 7:00 a.m., he seemed to be a little
faster and smoother than the observer believes would  be normal.   In this case,
the observer judges that John Doe Is working about 10 percent faster than  the
normal employee.   (John must be judged against the normal employee, not himself
at another time.)  The observer therefore establishes a rating of 1.10 which is
equivalent to 110% of normal speed, thereby requiring a leveling of +10% of the
elapsed time to establish normal time.   Had John  Doe  worked  10% slower than
normal,  the rating would have been 0.90  (90% of normal).

     The rating is multiplied times the  total  elapsed time and the result  is
recorded on the form as normal time.  If multiple observations were made,  the
form illustrated in Figure 2 would be used for all subsequent calculations;
however, in this case, only a single observation  is Illustrated.

     To estimate the allowance, one notes the  unavoidable delays.  In  this
case, in step 12, there was an unavoidable delay of 0.35 minutes.  This delay
is approximately 5% of the normal time (actually  4.48%  but  rounded upward
because of estimating difficulties).  The allowance is  therefore  established at
1.05 (equivalent to 105%) and multiplied times the normal time.   The result,
standard time,  Is recorded on the form and is  the final product.

     It ia hoped, as a result of this session, that the reader understands the
difficulties as well as the process of making  a time  study.  The  end objective
is to arrive at a fair estimate of  the time required  by a qualified operator
working at a normal pace which will not  induce fatigue  to perform the work over
and over.

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                                                                          10
                                  REFERENCES

1.  The Laboratory Management and Planning Committee.   Laboratory Workload
    Recording Meth.  College of American Pathologists,  7400 Skokie Boulevard,
    Skokie, Illinois 60076,  U.S.A.

2.  Canadian Schedule of Unit Values for Clinical Laboratory Procedures.
    Hospitals Section, Health Division,  Statistics Canada, Ottawa, Ontario, K1A
    OT6.  Canada.

3.  Work Time Unltst  A DlagnoBtic  Workload Measurement Structure for Public
    Health Laboratories.  Center for Disease Control,  U.S. Public Health
    Service, U.S. D.H.E.W.,  Atlanta, Georgia 30333.

4.  Antis, William.  Stopwatch Time Study.  Chapter 2  in Industrial Engineering
    Handbook, Maynard, H.B.  ed.  Third edition.   McGraw-Hill Book Company, New
    York.  1971.  pp. 3-12 - 3-27.

5.  Taylor, Frederick W.  The Principles of Scientific  Management. Harper and
    Brothers.  New York.  1911.

6.  Smalley, Harold E. and John R.  Freeman.  Hospital  Industrial Engineering.
    Relnhold Publishing Corp.  New York.  1966.

7.  Wertlake, Paul T.  "The Performance  Critique Team:   Maximizing Lab
    Efficiency."  Laboratory Management.  September, 1974.  pp.  49-50.

8.  Slnton, Eleanor B.  "Workload Recording:  Now You  Need It More Than Ever."
    Medical Laboratory Observer.  May, 1976.  pp. 127-137.

9.  Production Handbook.  3rd edition.  Carson,  Gordon  B., Harold A. Bolz, and
    Hewitt H. Young, editors.  Ronald Press Co.   New York.  1972.  Section 12,
    pp 1-104.

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                                      Inorganic Section
         Test                             W 1 ij

Apparent Color                             2
True Color                                  2
Turbidity                                   >f
Settleable Residue                          2
Suspended Residue                          9
Total Residue                              10
Dissolved Residue                          10
Volatile Residue                             )
Fluoride                                    k
Total I iardness                              <\
Calcium Hardness                           >i
Dissolved Oxygen                           5
BOD                                      20
MDAS                                      20
Total Organic Carbon                       22
Phenol                                     20
Cyanide                                   20
Oil & Grease                               30
Tannin and Li^nin                          10
Silica                                      10
Boron                                      20
Cr   Chromium-Hex                        10
Sulfate                                      2
Sulfide                                     25
Cr   Chromium-Tri                          1
EPToxicity
Ignitability                                 60
EP Toxicity Cyanide                        50
Fish Extract                               30
Chlorine Residual                            5
Acidity Total                               30
Alkalinity Net                              30
Alkalinity Total                             '»
Alkalinity Plienolplitlialein                   it
Acidity                                     (»
Chloride                                    fj
Specific Conductance                        3
pH                                          2
Flame A. A.                                 3
Furnace A. A.                               20
Cold Vapor A.A. (Water & Soil)              12
Cold Vapor A.A. (Fish)                      30
Flame A.A. (Fish)                           60
Hydride A.A. (Fish)                         60
TKN                                       20
Total Phosphorous                          15
Nitrate and Nitrite                         10

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                                      Inorganic Section
        Test                             WTU

Ammonia                                  10
COD                                       10
Nitrite                                     JO
Organic Nitrogen                            I
Sulfur                                     120
Precipitation                                3
Weight                                      1
Nitrate N                                   1

Air Pollution:

Metals, Prepared                           ^2
Metals, Run                    '             3
TSP, Exposed                               15
TSP, Unexposed                             5
Gas Chromatograpli                        120
Silt                                        20
Asbestos (Ashing)                           12

Stack Stampling:
    Tilters                                 20
    Acetone Wash                          15
    Front Glass Wash                       15
    Itnpinger,  Ele. Temp.                    1 5
    Impinger,  Chloroform                   35
    Documentation                          6
    Mercury                               '40
    Formaklehyde                          60
    Fluoride (Dental)                        <»
    Fluoride (Other)                         <4

    502                                   3°

Coal:
    % Moisture                            15
    96 Ash                                 15
    % Sulfur                              120
    DTU                                  120
    Bulk  Density                           15

Saroad                                      3
High Volume Microscopic                    '»5
Asbestos (school)                           35
Asbestos (other, microscopic)                15
Radiation alert filter study                   3

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                                     inorganic Section





        Test                             WTU

                               Radiological Chemistry Section

Gross Alpha-Beta; soil, water                60
Gross Alpha-Beta; air filters                  5
Gross lieta;  vegetation                      60
Specified Alpha; soil                       720
Gamma Analysis                            60
Iodine - 131  by ppt                         210
Plutonium; water                          2^0
Radium 226, 228                           <*20
Strontium 89, 90                           300
Total Thorium                             300
Total Uranium                 "            300
Tritium (Liquids)                            30
Uranium <5c Thorium Isotopic                5'*0
Leak Test: (Alpha-beta)                     60
     Scintillation  vials                      30
ERAMS: Air Filter Study                     8
     Precipitation Study                      5


                                      Organic Section
        Test
Purgeable Halocarbons
Purgeable Aromatics                      '*20
Acrolein Acrylonitrile                     120
Phenols                                   120
Denzidines                                120
Phthalate Esters                          120
Nitrosoamines                             120
OrganocMorine Pesticides & PCtt's          120
Nitroaromatics & Isophorone               120
Polynuclear Aromatics                     120
Haloethers                                120
Chlorinated Hydrocarbons                  120
Herbicides                                17<*
Petroleum Products                       120
Water Extraction:
     Base Neutral                           60
     Acid                                  60
Sediment Extraction                       510
Tissue Extraction                          330
GC/MS                                   480
TOG                                    22.2
Polyurethane Foam Plugs                  420
Nitrobodies                                90
Cotton Swab Extracts                     2<*0
Pul  Extraction                            120

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                                   Aquatic Biology Section
        Test                             WTU

Bacteriological Analyses

Sewage Treatment Effluent                 20
Streams                                   20
Special (Wells, etc.)                         20

Biological Samples Collected

Qualitative Fish Samples                    90
Fish Samples for Toxics                     90
Fish Population Studies                   1800
3 sq. ft. Surber                             90
Selected Pickings               .            90
Dendy (ayt. substrate)                       90
Periphy toineters                          180
4 L. Plankton                               90
Chlorophyll                                 90
Chemical - (Routine  - Ambient)              90

Biological Samples Analyses

Surber                                    900
Selected Pickings                          720
Dendy                                    900
Periphy ton Biomass                        600
Periphy ton (Taxonomy)                     600
Plankton                                  600
Chlorophyll                                 90

Bioassays

Flow Through                             3540
Definitive                                1300
Static                                      90
Chronic-Ceriodaphmia                     3540
Chronic-Fish                             3540
Chemical Analyses Performed by Biologists   1 5
Plant Visits                                150
Training                                  050
208 Reviews                              l'(40
404 Reviews                               660
AGPT                                     080
Algal Toxicity                             480
Proj27

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