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MAINTAINING THE ENFORCEMENT INFRASTRUCTURE:
COMPLIANCE INSPECTOR TRAINING
IN 1992
REGIONAL REPORT
Prepared by
Compliance Policy and Planning Brancn
Office of Enforcement
U.S. Environmental Protection Agency
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ACKNOWLEDGEMENTS
The National Inspector/Supervisor Survey was designed by the
Compliance Policy and Planning Branch (CPPB) of the Office of
Enforcement (OE) with the extensive support and input from EPA's
Regions, NEIC and Headquarters Compliance .Programs. National
Enforcement Training Institute (NETI) provided contractor support
for the development of the computerized survey.
The Project Manager and principal author was Rebecca A. Barclay,
Program Analyst. In addition to helping with the survey design, HQ
and Regional Project Contacts organized the collection/ completion
and submission of survey information for their respective organiza-
tions. In most instances, they did this complex task with the
assistance of several other staff members. The Principal Project
Contacts include the following:
Regions Principal Project Contacts
I Cindy Maynard
II Laura Livingston
III Robert Kramer
IV Scott Gordon
V Judy Kirman
VI Robert Clark
vii Rick Smith
VIII Jane Chadbourne
IX Fred Leif*
X Diane Ruthruff
NEIC Gene Lubianiecki
Headquarters
Air Mobile Sources Ann Bailey
Air Stationary Sources Mark Siegler
Pesticides and Toxics Pam Saunders
Superfund (CERCLA) Oebby Thomas
* Special thanks .to Fred Leif in Region IX for testing the survey
software twice and suggesting important ways to make the survey
easier to understand and answer.
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MAimiUJG TIE O7IASTUKTUM:
ISPKTOI T1MII1G 01 1992
SOMilT
o This report counts individual inspectors on-
board as of the 10/1/92 in fourteen EPA
organizations, across nineteen proqrais. It
contains statistics on completion rates for two
types of required training: Health and Safety, and
Basic.
o Infonation on completion of Prograi-Spcific
Minima Training (PSMT) will be analyzed in a
separate report. This separation is important
because EPA has inspectors with multiple prograi
assignments. As a result, any accounting of
inspector training on a progra-by-prograi basis
inevitably requires double counting of inspectors,
and that method inflates the number of individual
inspectors. To avoid misinterpretation, a separate
report on PSMT is needed.
A. FACTS 01 Til TOTAL DUWKI
of amnn IISPKTOIS
Mon-CElCLA Inspectors
CSBCLA OSCs and RPfe
Total Universe
1,241 (63*)
719 (37*)
1,960 (100*)
o Tie universe has increased by 320 individuals
compared to the universe reported in the Inspector
Profile (May 1987). Tvo thirds of this increase
(210 or about 661) is accounted for by CEKLA OSCs
and RPIS. The other one third (110 or aixwt 33*)
are distributed among the other proqrais.
C. FACTS ABOUT CHCLi TULHTJG
Health 4 Safety (HST)
Basic (BT)
Total OSCs and 8PSs =
iational
Completion lates
420
440
719
(Sit)
(1001)
o These1 rates are considerably lower than for the
Jfon-CBKLA inspectors. Tvo Regions (III and IV)
report Fair rates by exceeding the national rate.
Four legions (legions II, V, VI , Vlll) report
Mixed Results bat nearly equal the national rates
of training, whiile four other legions (legions I
VII, II and X report Very Miied Jesuits, by being
belov the national rates.
D. cwoiSM or 1992 uns NITI
1990 liRS Or TiAIHK HSPSCTOE
1239 1222
60* 831
50* 89*
Health and Safety
Basic
o The greatest increase over 1990 is in BT. The
pattern is similar for supervisors, but their
overall rates were lover in 1990 and remain lover
ia 1992.
B. FACTS AfiODT KM-OKLl THIHJ6
Iational
Health i Safety (Bf)
Basic (Bf)
Total Mon-CEKU Inspectors
1,026 (83*)
1,105 (89*)
1,241 (100*)
o Four organizations (legions I, II, aid VIII and
HQ Air Stationary Sources) report Very Good
results, by equaling or exceeding the national
rates. Four organizations nave Miied leaults
(Regions II, VI, x and BQ Pest/Tox) aHile six
others (legions IV, v, VII, II, i!IC and IQ Air
Mobiles Sources have Very liied Results1.
of
1. KSTH&TB) FDTulI TIAHTK KSDS
1992 1993
(Inspectors t OSCs/lPSs)
(Supervisors)
Basic
(Inspectors t OSCs/IPfe)
(Supervisors)
Total
215 1,960
_ifi J21
275 2,191
Total
136
_42
183
294
_^S
319
o SST annual refresher means a very large annual
training population
o Bf is a one tiie only requirement and future
needs relate to turnover. Assume turnover rates of
15* for inspectors and 11* for supervisors.
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P. risptjfl'M TtAnmc rot THE
o Institutional! zation of training at EPA is a
difficult tasJt in general, and is exceedingly
coiplex for the universe of appliance inspectors
and supervisors spread across 19 program and 14
organizations.
o This report identifies issues in four areas that
EPA needs to address to place inspector training on
a fin footing: 1) direction and priority of
supervisor training under 3500.1; 2) future of
health and safety training; 3) future of basic
training; and 4) future of record keeping and
national and regional reporting
o OE vill revise these issues based on rcviev by
the Regions and Headquarters Oapliance Program
and vill vork vith the Inspector Training Advisory
Board (ITAB) to develop options and reconendations
to address these issues during FT 1993.
o These vill be in the fon of a set of issue
papers to be prepared for discussion vith the ITAB.
Decisions on these issues vill be reflected in
revisions to EPA Order 3500.1. Decisions
concerning the future Prograi-Specific Minimi
Training vill also be addressed in the revised
Order. OE vill follow the saw process for issues
pertaining to Prograi-Specific Minima Training.
and incorporate these decisions in the final
revised Order as appropriate.
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KAINTAIlfI*G THE HrFOKHKr DrFRASTBOCTUJE;
COHPLIAKE HSPBCTOR TRAIUK II 1992
TABLE OF CMTfflTS
E1KDTTV1
A. Dni verse loo-CESCLA Supervisors
B. Onpletioa Rates for Health and Safety Training
and Basic Training
Pages
I. IHnOOOCTIOf 1 - 3
A. Background
B. Purpose
C. Organization of Report
II. METHODOLOGY AID DATA QUALITY 4-7
A. Defining the Universe of Inspectors
B. Measures of Training Completed
C. Current Status of Information Sources
III. UMIVERSE OF ALL HSPECT01S 8-10
A. National Universe of All Inspectors
(CERCLA and Non-CEKLA)
B. Distribution of All Inspectors by Organization
IV. DHIVBSE OF gQKHKLA HSPKTMS 11 - 17
W TPH TRAH1116 RATES
A. Non-CEKLA Universe
B. Completion Rates for Health and Safety Training
and Basic Training
V. rcffTVBtSB PF CEKLA OSC§ Ajp KPH5 18 - 21
AID THEI1 Tmmc BATES
A. Universe of CEKLA OSCs and XPRs
B. Coipletion Rates for Health and Safety Training
and Basic Training
VI. DITVHSE OF JOt-CaCLA SDPPVISMS 22-27
Am frara TMnmc
VII. "KAimTTQBfi HTflniTffH? 28-33
A. Hon-CZRCLA Highlights Organization by Organization
B. Frequency of Regional Rates Above
National Rates (Kon-CEKLA)
C. CEKLA Highlights Region by Region
D. Frequency of Regional Rates Above
National Rates (CEKLA)
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OOiCLOSIOiS 34 . 39
A. Comparison of National Traininq Sates in 1992
to National Sates in 1990
B. Inspector Training Needs
C. Supervisor Traininq Needs
0. Estimated Future Traininq Needs (1993 and Beyond)
IX. HSPECTOi TMnmc KH THE FDTC1E; ISSDES/IBED6 39 - 42
A. Direction and Priority of Supervisor
Traininq Dnder 3500.1
B. Future of Health and Safety Traininq
C. Future of Basic Traininq
D. Future of Secord Keepinq and
National and Seqional Report Reporting
E. Next Steps
APPHDII A. MATIOUL DEPECTOS/SCPHVISOi TIAIH1G SD1VKT
APPODIX B. STATUS OF CBKLA STAFF GMPUAICE WITH
EPA OKDE1 3500.1
APPBDII C. 1990 IKPKT01 TXAHHG 1EFOBS
APPODIX D. SPUADSHER SOBAIIKS
1. liSPECTOKS (CEKLA AND HOf-CZSOi)
2. INSPECTOSS (NOI-CEKLA ONLY)
3. CESCLA OSCS AND SPB
4. SOPESVISOiS (NOH-CEKLA OJfLY)
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MAINTAINING THE ENFORCEMENT INFRASTRUCTURE:
COMPLIANCE INSPECTOR TRAINING IN 1992
I. INTRODUCTION
A. Background
Working with the Headquarters' Compliance Programs and
Regions, the Office of Enforcement (OE) has assessed the types of
training completed by compliance inspectors/investigators and
supervisors of inspectors, as required under EPA Order 3500.1, on
Inspector Training and Development.1 The requirements for
inspector training were phased in over a three year period
beginning in June 1988. The Order directed OE to evaluate
progress with inspector training at the end of this implemen-
tation period. This report constitutes part of that evaluation.
EPA Order 3500.1 reiterated the requirements for Health and
Safety Training (HST) embodied in EPA Orders 1440.2 and 1440.3.
In addition, it required that Basic Training (BT) and Program-
Specific Minimum Training (PSMT) be completed before an inspector
independently conducts or leads an inspection.3 All EPA
personnel who independently conduct or lead compliance
inspections are subject to 3500.1, regardless of the amount of
time they spend in this function. First-line supervisors of
inspectors are also subject to the Order.
To carry out this assessment, OE designed computerized
survey forms on inspector training during FY 1992 with contract
support from the National Enforcement Training Institute (NETI).
Region IX was instrumental in two rounds of testing those forms
and recommending changes and improvements. This report contains
the results of the National Inspector/ Supervisor Training
Survey. The National Survey covered eighteen (18) programs, of
which five were sub-programs of Air Stationary Sources. See
Appendix A for more information about the development and
contents of the survey; a copy of the survey forms; and a list of
programs covered.
x. Throughout the report, the term "compliance
inspector(s)" includes field investigators who are subject to
EPA Order 3500.1, such as CERCLA On-Scene Coordinators (OSCs)and
Remedial Project Managers (RPMs), and investigators for the
Wetlands Protection Program.
3 EPA Order 3500.1 does not apply to state and local
personnel because it is an internal regulation. However, EPA
supports their compliance and enforcement training programs in
several ways. One of these is by publicizing EPA delivered or
EPA sponsored courses and inviting state and local compliance
personnel to participate. Another is by training state personnel
to serve as instructors for inspector training using materials
developed by EPA. Several EPA programs collect statistics on the
training of state and local personnel but these are not included
in this report.
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Information on training completed by CERCLA personnel, the
nineteenth (19th) program covered in this report, was derived
from a separate database as described below in Part II.
METHODOLOGY AND DATA QUALITY, and in Appendix B. Status Of CERCLA
Staff Compliance with EPA Order 3500.l.
Fourteen (14) EPA organizations provided information for the
survey. These include all ten (10) Regions, the National
Enforcement Investigations Center (NEIC) and three Compliance
Programs with inspectors based in Headquarters. The three
Compliance Programs with inspectors based in Headquarters include
the following: Air-Mobile Sources, Air-Stationary Sources, and
Pesticides and Toxic Substances. These latter three sets of
inspectors are grouped together under the term "Headquarters" in
the remainder of this report. As a result, the tables, graphs
and spreadsheets appearing throughout the report show information
for twelve (12) organizations rather than fourteen (14).
B. Purpose
The National Inspector/Supervisor Training Survey had two
primary purposes: 1) to count the total number of individuals
who function as lead compliance inspectors/investigators for EPA
and who were on-board as of October 1, 1992'; and 2) to assess
who has completed the training required by EPA Order 3500.1.
The first purpose is very important because EPA has not
updated figures on the number of individual inspectors since the
original Inspector Profile, prepared by Region II (dated May
1987). At that time EPA identified 1,640 compliance inspectors
leading or independently conducting compliance inspections in
twelve organizations. About one-third of these were CERCLA
personnel. In reviewing this earlier Profile, the Regions and OE
strongly agreed that the number of individual inspectors should
be updated in the national survey. This agreement created the
necessity for computerized survey forms.
The second purpose of the national survey is to assess
whether inspectors were receiving the three types of required
training. The Regions and OE agreed to focus the survey
particularly on the status of Program-Specific Minimum Training
(PSMT) because OE's earlier assessment of training in 1990 had
revealed lower completion rates for this PSMT than for other
types of training across most programs and most organizations.
(See Appendix c for a description of OE's previous efforts with
the Regions to assess progress with inspector training in 1990).
Another reason for focusing on PSMT was to identify all of the
current program-specific assignments of different individuals in
order to have a general indicator of inspectors with cross-
program training.
3In practice, several Regions reported inspectors who were
hired during the first quarter of FY 1993 (October 1-December 31,
1992).
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C. Organization of the Report
1. Universe of Inspectors
This report describes the universe of individual inspectors
and supervisors by organization, by year of assignment to current
duties, and by number of program assignments. Then the report
provides statistics on who completed training by consolidating
information across programs for each organization. The same
information is provided for first-line supervisors of inspectors.
Note that individual inspectors do not represent FTEs. See
PART II. METHODOLOGY AND DATA QUALITY for additional explanation
of this fact.
2. Counting Each Inspectors Once and Only Once
This report counts each individual inspector because this
method gives the most accurate number of inspectors that EPA
employs. The statistics in this report are based on counting
each inspector or supervisor once and only once in the completion
rates for two types of training for which this is possible —
Health and Safety Training (HST) and for Basic Training (BT).
This method also offers the most realistic measure of Regional
accomplishments in training because the Regions were primarily
responsible for delivery of HST and BT .to their employees either
using contractors or other third parties, or by using in-house
personnel as instructors.
3 . pojmJletion Rates for PTT0Trall~SpflCi^ ic Training Involve
Counting Insectors
This report does not include completion rates for Program-
Specific Minimum Training (PSMT). That information is organized
in a second report on the national status of program specific
training. The primary reason for this separation is that 231 or
12% of EPA inspectors have multiple program assignments as part
of their current inspection duties. This means that any
examination of the completion rates for PMST will necessarily
involve double-counting of inspectors.
For example, the total number of individual inspectors
reported in this survey in Region III is 209. But the total
number of inspectors reported by program in Region III is 264.
The second number reflects double counting of those inspectors
with multiple program assignments. This increase is accounted
for by 39 inspectors in Region III who reported assignments in
two or more programs areas. The same pattern holds true for
first-line supervisors. Keeping the analysis of the universe of
inspectors by organization separate from the analysis by program
is very important to avoid confusion about the actual number of
individual inspectors.
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II. METHODOLOGY AMfl DATA
There are several issues that affect the accuracy and
reliability of information in this report. Chief among these are
1) who is counted in the universe of compliance inspectors or
supervisors who are subject to the Order; 2) what are meaningful
ways of measuring the training that has been completed; and 3)
what are the sources of information for these measures and how
are they organized.
A. Defining the Universe of Inspectors
Identifying who is subject to EPA Order 3500.1 has been a
primary task of Regional managers, and of those managers with
inspectors based in Headquarters. This task has been complex
because the term "compliance inspector" is not a job title nor
job classification. Therefore, standard EPA personnel databases
do not automatically reveal who performs this function.
1. Special Process to Identify Inspectors
Instead each organization must undertake a special process
of identifying the compliance inspectors by managers who
supervise such personnel. Defining this universe and keeping it
current as turnover occurs is essential to enable needs
assessments, effective delivery of training, and tracking whether
the inspector has satisfied applicable training requirements.
Several Regional Project Contacts for the National Survey.
indicated that completion of the survey was the most valuable
tool in recent years for encouraging the Regions to keep their
"universe" up to date.
2. "Lead Inspectors" are Covered by 3500.1
All personnel who independently conduct or lead compliance
inspections are subject to the EPA Order 3500.1. This definition
focuses training on those inspectors who go "solo1* to a facility
or site, or who are leaders of team inspections whether they do
it once per year or fifty times per year. In the remainder of
this report, the term "inspector" will be used in lieu of the
term "lead inspector".
The inspector Profile (May 1987) prepared by Region II for
the Agency-Hide Work Group on Inspector Training and Development
was the first ever study of the universe of compliance inspectors
at EPA. This report revealed that about two thirds (66%) of
1,640 personnel who identified themselves as inspectors performed
this function 20% or less of their time. This means that the
compliance inspection function is widely dispersed among many
people at EPA. Therefore, three or four individuals may account
for one (1) FTE's worth of inspections. If, for example, each of
these three or four individuals leads or independently conducts
NPDES inspections, then each must be fully trained in NPDES
Program-Specific Minimum Training. To save training costs, some
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Regions have re-assessed who will lead inspections in an effort
to consolidate responsibilities and reduce training costs, other
Regions want the flexibility offered by having more personnel
trained as lead inspectors.
B.
1. Completion of Bach Type of Training
Measuring the progress in completing each type of training
is important. This approach gives credit to the inspector who
completed some, but not all, types of training, and highlights
where training has yet to be completed. Looking closely at the
completion rates of different types of training is important
because different organizations are responsible for development
and delivery of the different types of training. To change or
improve the rates of completion, EPA managers need to know which
organizations are responsible.
For example, OE is responsible for developing and updating
BT, but the Regions are responsible for delivery. The Safety,
Health and Environmental Management Division (SHEMD) in the
Office of Administration and Resources Management (OARM) is
responsible for development of training but Regions play a
primary role in delivery of HST under EPA Orders 1440.2 and
1440.3. The HQ Compliance Programs are primarily responsible for
development of PMST; the programs and Regions are jointly
responsible for delivery of this type of training. (Note: in
some situations, Regions will develop courses for specialized or
unmet needs.)
This report analyzes the numbers of inspectors who completed
two types of training—HST and BT only—for reasons described
above in PART I. IMTRODUCTIOM. Therefore, this report should be
most useful to the following groups: 1) the managers in
Headquarters, the Regions and NEIC who are responsible for
development and delivery of HST and BT, and 2) the first-line
supervisors of inspectors who have primary responsibility for
informing inspectors of the training requirements; communicating
training needs to those who plan and administer training
programs; ensuring that required training occurs; and for keeping
records shoving that required training has been completed.
In order for a compliance inspector to independently conduct
or to lead inspections, s/he must have completed all of the
required training. Required training consists of three types:
1) Health and Safety Training (HST); 2) Basic Training (BT); and
3) Program-Specific Minimum Training (PSMT). The primary measure
of progress, therefore, is how many inspectors completed all
requirements. This analysis depends first and foremost on
knowing who completed PMST. Because counting inspectors by
program results in double-counting of inspectors. The statistics
and analysis for this measure will be contained in a second
report where the training information is organized on a program-
by- program basis.
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c.
1. Responsibility for Tracking Rests Pri»»rilY
e Regions
Under EPA Order 3500.1, the tracking of the completion of or
exceptions from training requirements was a responsibility of the
program managers who supervise compliance inspectors/investi-
gators. Records of training should be kept by the Regions and by
those Compliance Programs with compliance inspectors based in
Headquarters. * The 1990 assessment of inspector training
revealed that no manual or automated systems that consolidated
information on all three types of training for an individual
compliance inspector existed in any Region. Since that time
several Regions (Regions II, IV, and IX) have organized
centralized and/or consolidated tracking systems, either manual
or computerized, for inspector training. These organizations
were able to respond to the National Survey most readily.
2. Decentralized Tracking is Still t»g Mora
Other organizations still rely on decentralized systems
drawing from varied sources of information within each Region. -
These sources include the following: automated tracking systems
for Health and Safety Training; automated tracking of Basic
Training; and manual searches of personnel files at the section,
branch or division level, or through the Human Resources
Division; and/or consultation directly with the inspector,
particularly for information on PSMT. Organizations with a
decentralized system or no particular system had much more
difficulty responding to the National Survey in an accurate and
timely way.
The source of information depends primarily on the type of
training — HST, BT or PSMT. In some Regions, Personnel Divisions
manage records of HST and BT. In other Regions, the Environmen-
tal Services Divisions (ESDs) manage records of HST. Records of
PSMT are usually found in the Program Divisions or ESDs. The
National Survey has again demonstrated that records of PSMT are
still elusive because tracking systems for PSMT have not been
established in the majority of Regions. Getting information on
PSMT was the most commonly reported difficulty in completing the
Natio
Raportina Process
Creation of the computerized survey forms enabled even those
Regions with the most fragmented arrangements for tracking to
respond more quickly to this National Survey than in 1990.
Several Regions had their LAN Administrator install the software
on the LAN, thereby allowing data input from several different
locations within the Region. This allowed speedier input, but
4 Section 9.e.(2) states that first-line supervisors of
inspectors are "responsible for maintaining records . . . ."
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this approach raises issues about the reliability and accuracy of
the information because review for quality was not assured.
However, several of these Regions found the software to be so
useful that they have decided to maintain and update the survey
forms as an on-going system for summarizing completion of
inspector training within their Regions.
Based on comments from the Project Contacts for the National
Survey. OE is aware that the quality of training information
varies from program-to-program and Region-to-Region. Based on
comments from this group, there may be both under- and over-
estimates of training completed, particularly for PMST. At the
present time, there are no ways to check data accuracy or
reliability other than audits of files or records of the Regions,
NEIC or the affected Headquarters Compliance Programs.
4. national Tracking of CERCLA Training
When EPA adopted the Superfund Academy system in 1989, OSWER
began tracking completion of CERCLA training nationally through
EPAYS, EPA's general personnel/payroll database. Regions report
data on training OSCs and RPMs to that system periodically, but
in recent years the system has not been updated frequently.
Therefore the Headquarters CERCLA program had to review the
information printouts and update them manually after consulting
with CERCLA Program Contacts in the Regions. This system doe not
track training of first-line supervisors of OSCs and RPNs;
therefore this report does not contain information on CERCLA
supervisors.
For purposes of this report, OE has combined information on
the total number of OSCs and RPMs with the information from the
National Survey in order to derive a total national count of
inspectors. However, OE could not combine information on
completion rates of training by CERCLA and Non-CERCLA personnel
and thereby provide national totals. Instead, the completion
rates for training Non-CERCLA personnel are analyzed and reported
separately from the completion rates for CERCLA personnel.
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III. UNIVERSE OF ALL INSPECTORS
A. National Universe of All Inspectors:
This section of the report describes the universe of all
inspectors (CERCLA and Non-CERCLA) from a national perspective by
consolidating information from the National Survey and the CERCLA
database. It was possible to combine information for only one
item from these two sources: the number of individual inspectors
on-board as of October 1, 1992. This universe is based on
counting individual inspectors once and only once in each
organization.
Figure 1 shows that EPA has a grand total of 1.960
individuals independently conducting or leading compliance
inspection and investigations among twelve (12) organizations and
nineteen (19) programs covered by the report. About two fifths
(40%1 or 719 are CERCLA, and the remaining lf241 or 60% are
distributed across the other programs.
Figure l
TOTAL EPA COMPLIANCE INSPECTORS
k * ftan-CaCLA » 1JB)
NCN
12*1 («UK)
71* GX.7X)
B. Distribution of All Inspectors bv Organization
Table 1 shows the relative distribution of all inspectors
(CERCLA and Non-CERCLA) among the twelve (12) organizations.
The number ranges from a high of 279 to a low of 41. Region II
has the largest number and percentage of inspectors, followed by
Regions III with the next largest number. NEIC has the smallest
number at 41. See Appendix D for all spreadsheets used in the
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analysis, including the spreadsheet that combines information
from the National Inspector/Supervisor Training Survey with
information from the CERCLA database.
Table 1.
Distribution of All Inspectors by Organizations
(CERCLA and Non-CERCLA)
Total
Region/ Individual
Organization Inspectors
* and %
I 184 9%
II 279 14%
III 258 13%
IV 181 9%
V 252 13%
VI 195 10%
VII 143 7%
VIII 96 5%
IX 158 8%
X 113 6%
National Enforcement 41 2%
Investigations Center (NEIC)
Headguarters (HQTRS) 60 3%
Total 1,960 100%
Figure 2 on the following page shows the proportion of
CERCLA and Non-CERCLA inspectors among the different or-
ganizations.
PARTS IV and V of the report analyze and display the
information on Non-CERCLA inspectors separately from the CERCLA
OSCs and RPMs because the CERCLA database did not contain all the
same data elements as the National Inspector/Supervisor Training
Survey. Each section provides a national summary of training
completed followed by a region-by-region analysis of information.
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Figure 2
10
JDO
INSPECTORS BY ORGANIZATION
(CEKL* * NW-QBCL* • uao)
it-a n-r *-• M-t n-io
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11
IV. UNIVERSE OF NON-CKRCLA INSPECTORS AND
THEIR TRAINING RATES
A. Non-CERCLA Universe = 1,241
The total number of non-CERCLA inspectors is 1,241. The
discussion of this universe includes four types of information:
1) the number of inspectors organization-by-organization;
2) the nunber of inspectors by year of assignment to current
duties; 3) the completion rates for HST; and 4) the completion
rates for BT.
The number of individual inspectors per organization appears
in Figure 3. Region III has the largest number at 176 or 14%,
Figure 3
xo
iao -
INSPECTORS BY ORGANIZATION
» - 12*1)
190 -
no -
t»l
130 -
110
100
9O -
to -
TO
00 -
90 -
«o
JO
»-f
LC7/10K!
Ys
I TV'**
•I
•0-X/
I
toa/«
I
ao/«
1
97/M
•o/ai
*!/»
I
N-l *-a »-J
!»-• (»-• M-7 »-• »-• M-IO
followed by Regions II (163) and V (154); NEIC has 41.
2 . Tnilftctors b Year Qf Aggignacn't to
Current Dufciea ( Non-CERCLA ) *
The section contains a national summary of inspectors by the
This report provides a summary of training completed
pertaining to the current duties of the inspector or supervisor.
It is not a complete history of all training that the inspector
may have had in prior positions.
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12
year of assignment to current duties, followed by an
organization-by-organization breakdown. The year of assignment
is an important factor affecting the completion rates of
training. In general, the longer that an inspector has been
employed in his/her current position the more time s/he has had
to complete training, or conversely the more recently assigned,
the less time s/he has had to have complete training, particu-
larly program specific training. This analysis examines two ends
of the spectrum, those assigned prior to 1988, and those assigned
in 1991 and 1992.
a.
National Sumarv
Figure 4 offers a national summary of the information on
year of assignment. In this figure four hundred thirteen (413)
or 33% of inspectors were assigned to their current duties prior
to 1988. That group has five or more years of experience.
Figure 4
INSPECTORS BY YEAR OF ASSIGNMENT
too*
I
210/17*
20V 1
121/17*
to*
7/7/s
V//A
Of the other eight hundred twenty-eight (828) inspectors, four
hundred sixteen (416) or about 50% assigned since 1991. This
group has two years or less of experience.
b. Assigned Prior to 1988
Regions vary from this national picture as shown in
two graphs, Figure 5 (Regions I-VI) and Figure 6 (Regions VII-X,
NEIC, and HQ), on the next page. For Regions I, II, III, X, and
NEIC are the organizations with the greatest percentage of
inspectors assigned to current duties prior to 1988. These range
from a 63% to 44% of inspectors. Regions IV and VII have the
-------
13
lowest percentages of inspectors assigned to current duties prior
to 1988 with 13% and 16% respectively.
c. Assigned in 1991 and 1992
Several Regions have a significant number of inspectors
assigned in the years 1991 and 1992. In 1991, the national rate
was 16%. Four organizations report about 20% - 28% of inspectors
were assigned to current duties. These include (Regions II, IV,
VI, and NEIC). Six other organizations (Regions I, V, VII. IX
and HQ) report 15% - 19% were assigned. Regions III and VII were
much lower at 5% and 8% respectively. These higher percentage of
recent assignments means that those organizations have a
increased training needs.
For 1992, Region VII reports that 37% of inspectors were
assigned to current duties; Region IX reports the next highest
rate at 30%.
Figure 5
YEAR OF ASSIGNMENT BY ORGANIZATION
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14
Four organizations (Region IV, V, VII, and NEIC) report between
20% and 25% assigned in this year. Five organizations (Region
I, III, VI, X and HQ) report between 10% and 19% assigned in this
year. Region II reports the lowest at 5%.
Figure 6
YEAR OF ASSIGNMENT BY ORGANIZATION
*»-tMi S3 i« EZ3 '•• 523
B.
for Health and Safetv Trainina
and Basic Trainirxi
This section shows a national sumary followed by a
breakdown on an organization-by-organization basis. The national
Table 2.
National Training Rates for Inspectors
National
Training
Health and Safety
Basic
Total Mon-CBRCLA Inspectors
1,026 ( 83%)
1,105 ( 89%)
1,241 (100%)
training rate for HST is 83% while the national rate for BT is
slightly higher at 89%.
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15
1. Hgylt^fr and Safety Training (Figure 7)
a. Definition of Completion
EPA's Health and Safety Training Orders 1440.2 and 1440.3
establish initial and annual refresher training requirements.
These requirements pertain to EPA personnel regardless of job
classification. That is, they pertain to any and all EPA
personnel who visit non-EPA facilities or sites. For purposes of
the National Survey, an inspector was counted as completing HST
if s/he had completed training to satisfy the applicable training
requirements—either the initial training or the annual refresher
in calendar year 1992.
b. SiMMT-y
The national completion rate for HST is 83% or 1,026. The
rates range from a high of 93% to a low of 38%. For HST, eight
(8) organizations (Regions I, II, V, VI, VIII, IX, X and NEIC)
report completion rates well above the national rate by being at
90% or higher. Four (4) organizations (Regions III, IV, VII and
HQ) are below the national rate. Among these four, HQ shows the
Figure 7
7o INSPECTORS COMPLETING H&S TRAINING
1
I
HOC
100X
SOX
aox
7051
aox
so*
to*
ox
113
1JB
I
i
143
1
I
74
I
37
I
u
I
R-f M-7
(*-» ft-tO I«C MOM
lowest completion rate because of the very low rate (17%)
reported by Air-Mobile Source Program. However, another HQ
program, Air-stationary Sources, reported the only
completion rate for HST.
-------
2.
a.
16
(Figure 8)
Definition of Completion
For purposes of the National Surveyr an inspector was
counted as having satisfied the requirement for Basic Training,
if s/he completed the "Fundamentals of Environmental Compliance
Monitoring Inspections," course or received an exception to this
requirement. As a matter of Regional policy, most Regions did
not grant exceptions to the Basic Training requirement, although
EPA Order 3500.1 provided that option for inspectors who met
certain criteria. Therefore, the numbers in this section of the
report represent inspectors who attended a training class
provided within the Region. The number of inspectors receiving
an exception for Basic Training was very small or zero in the
majority of Regions
and HQ.
This point is important because those Regions (eight of ten)
and HQ that provided the course using in-house personnel did so
without receiving any new resources from OE or the Program
Offices for this activity over the last three-four years. For
larger Regions and those Regions with higher turnover rates, this
meant expending significant resources on administration, teaching
and attendance.
Figure 8
H01C
ICO*
90*
aox
*»
% INSPECTORS COMPLETING BASIC TRAINING
I0r*« 1,108)
OK
117
^
y/
//
Sj
taa
1
101
I
138
I
ta
I
73
1
39
I
76
97
I
30
I
M
H-J ft-4
fl-7
b.
The national completion rate for Basic Training 89% or
1,105. The rates range from a high of 100% to a law. of 73%.
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17
Region X is the only organization reporting 100% of their
inspector have completed BT. Six organizations (Regions I,
II,IV, VIII, and IX and HQ) report completion rates at 90% or
greater for BT. Regions III and VI equal the national rate.
And three Regions (Region V, VII and NEIC are below the national
rate.
-------
18
V.
THEIR TRAINING RATES
This section of the report is based on information reported
in the CERCLA database for ten (10) Regions. There are no OSCs
and RPMs based in HQ therefore that organization is not included
in this analysis. NEIC does not report on CERCLA training for
its personnel in this database; therefore NEIC is not included in
this section. However, all NEIC personnel who are inspectors
have already been counted in the Non-CERCLA universe of
inspectors that was analyzed in Part III above. If the NEIC
inspectors were included here as well, that would result in
double counting of NEIC inspectors which conflicts with the
primary purpose of this report—to focus on the number of
individual inspectors, regardless of the number of program
assignments they have. Therefore, NEIC is not included in this
analysis.
The discussion of this the universe of CERCLA OSCs and RPMs
includes three types of information that is similar to the
information on the Non-CERCLA universe. These items include the
following: 1) the number of inspectors organization-by-
organization; 2) the completion rates for HST; and 3) the
completion rates for BT.
A. Universe of CERCLA OSCs and RPMS; Total = 719
The total number of CERCLA OSCs and RPMs is seven hundred
nineteen (719). Figure 9 shows the distribution of OSCs and RPMs
per organization. Region II has the largest number at
Figure 9
u
CERCLA OSCs & RPMs BY ORGANIZATION
(cacu to* • Til)
tao -
no •
too
9O
ao
70
m
so
40
20
to
0
r/.
1
*«
1
i.
M-1
H-7 ft-« H-* H-1O
116 or 16% of the national total, followed by Region V with
98 or 14%. Region VII has the fewest with 48 OSCs and RPMs.
-------
B.
19
Completion Rates for Health and Safety Training
andBasic Inspector Training
This section shows the completion rates of training first
from a national perspective, and then from a regional
perspective. For more details on the completion rates of
training for OSCs and RPMs see Appendix Br status of CERCLA
Compliance with EPA Order 3500.1.
Table 3.
National Sunary of Training Completed
Training
Health and Safety
Basic
Total OSCs and RPMs =
National
Cp,MpJ.etion Rates
420 (58%)
440 (61%)
719 (100%)
The national completion rate for HST is 420 or 58% while the
national rate for BT is slightly higher at 440 or 61%.
1. Health and Safety Training (Figure 10)
a. Definition of Completion
EPA's Health and Safety Training Orders 1440.2 and 1440.3
establish initial, advanced and refresher training requirements
Figure 10
1
I
too*
% OSCa & RPMs COMPLETING H&S TRAINING
Ccacu or* • «ao)
90X -
70S -
an
10*
01
I i
aa
!
a-a
-------
20
for CERCLA personnel. The information in the CERCLA database
pertains either to the initial, advanced or the refresher
requirements. The office that generated this data could not
distinguish whether the currently applicable requirement had been
satisfied. All that is known is that some HST has been
completed. Whether the CERCLA OSC has satisfied the current
requirement is not known. Therefore the information on HST
completed by CERCLA personnel is not comparably to the
information on HST completed by the Non-CERCLA universe of
inspectors and comparisons are not meaningful. However, this is
the best information OSWER had available for this report.
b.
The national completion rate for HST is 420 or 58%. The
completion rates range from a high of 71% to a low of 45%.
For HST, Region IV reports the highest completion rate of 71%.
Regions III and V are above the national rate while the rates of
Regions I, II, VI and VIII equal the national rate. Three
Regions (Regions VII, IX and X) are below the national rate.
Region X reports the lowest rate at 45%.
2. Basic Training (Figure 11)
a. Definition of Completion
For purposes of this report, CERCLA's Enforcement Training
Course and the Enforcement Training through the Superfund Academy
(1989-1991) are considered comparable to the Basic Training
required under 3500.1. For more details on how an OSC or RPM
could satisfy this requirement, see Appendix B.
Figure 11
100K
7. OSCs & RPMa COMPLETING BASIC TRAINING
(cacu a* • 4*0)
v
aox -
aox-
70X-
aox -
aox •
40* -
JDX
aox -
tox -
ox
73
'
41
R-I
ft-J
ft-4 M-7
(*-» ft-IO
-------
21
The national completion rate for BT (or the equivalent
Enforcement Training) is 440 or 61%, slightly higher than for
HST. The completion rates range from a lligh. of 78% to a
low of 48%. Region IV reports the highest rate at 78% and Region
III is the next highest at 67%. Five Regions (Regions II, V, VI,
VII, and VIII) report completion rates equal to the national rate
for BT. Three Regions (Regions I, IX and X) are below the
national rate, with Region X reporting the lowest rate of 48%.
-------
VI.
22
UNIVERSE OF MQM-gERCIA SUPERVISORS AMD
THEIR TRAIMTWr: PATKS
This part of the report analyzes the universe of first-line
supervisors of inspectors with all programs other than CERCLA,
using information from the National Survey. The discussion of
this universe includes four types of information: 1) the number
of inspectors organization-by-organization; 2) the number of
inspectors by year of assignment to current duties; 3) the
completion rates for HST; and 4) the completion rates for BT.
A. Universe of Non—CERCIA Supervisors: Total = 231
The total number of non-CERCLA supervisors is two hundred
thirty one (231).
The number of first line supervisors of inspectors per
organization appears in Figure 12. Region III has the largest
number at thirty-three (33) or 14% of the national total,
followed by Region II with twenty-eight (28) or 12% of the
Figure 12
TOTAL FIRST-LINE
JO -
SUPERVISORS
• 231)
national total. Region VIII reports the smallest number at six
(6) or 3% of first-line supervisors. The median number of first-
line supervisors is eighteen (18).
-------
23
Supervisors by Year of Assignment to
t D 6
2.
The section contains a national summary of supervisors by
the year of assignment to current duties, followed by an
organization-by-organization breakdown. This analysis focuses on
the two ends of the spectrum, those assigned prior to 1988 and
those assigned to current duties in 1991 and 1992. Informing
these new supervisors about EPA Order 3500.1 and their responsi-
bilities under it, and providing training to satisfy appli-
cable requirements is critical because supervisors are the key to
ensuring that training is planned and occurs, particularly for
other new employees.
a. national SuMMary
Figure 13 offers a national summary of the information on
year of assignment. In this figure, one hundred eighteen (118)
or 51% of supervisors were assigned to their current duties prior
to 1988. (This is a much greater proportion than that for
inspectors assigned to current duties prior to 1988.) Of the
entire universe of first-line supervisors, about one tenth were
assigned within each of the years — 1990 to 1992.
Figure 13
SUPERVISORS BY YEAR OF ASSIGNMENT
100*
V
b.
Figure 14 (Regions I-VI) and Figure 15 (Region VII-X, NEIC
and HQ) show the regional variation from the national picture.
"This report provides a summary of training completed
pertaining to the current duties of the supervisor. It is not a
complete history of all training that the supervisor may have had
in prior positions.
-------
24
One organization, NEIC, has 100% of its supervisors assigned
prior to 1988. Seven other organizations (Regions I, II, in, v,
VIII, X and HQ) have about 50% assigned prior to 1988 or about
Figure 14
YEAR OF ASSIGNMENT BY ORGANIZATION
Figure 15
YEAR OF ASSIGNMENT BY ORGANIZATION
d-7
the same as the national rate. Only three organizations have
less than 50 %. These include Region VI and VII at roughly 35%
each and the lowest is Region III with 8% of supervisors assigned
prior to 1988.
-------
25
c. Assigned in 1991 or 1992
Several Regions have assigned more supervisors in the last
few years. In 1991, Region VI assigned about 35% and the
majority of other Regions assigned less than 10%. In 1992, Region
IX assigned 25% and three organizations (Regions II, VIII, and
HQ) assigned between 10% and 20%. Another six (Regions I, ill,
V, VI, VII, and NEIC) assigned less than 10%. Regions IV and IX
are unique with half 50% of their supervisors being assigned in
either 1991 or 1992.
B. Supervisors/ Completion Rates for Health and Safety
Training and Basic Inspector Training
This sections provides a national summary of training
completed by non-CERCLA supervisors, followed by an analysis on
an organization-by-organization basis.
Table 4.
National Training Rates
National
Training Completion Rates
Health and Safety 171 ( 74%)
Basic 184 ( 80%)
Non-CERCLA Supervisors = 231 (100%)
1. Health and Safety Training (Figure 16)
a. Definition of Completion
EPA's Health and Safety Training Orders 1440.2 and 1440.3
establish initial and refresher training requirements. These
requirements pertain to any personnel regardless of job
classification who visit non-EPA facilities or sites. For
purposes of the National Inspector /Supervisor Training Survey r OE
used the save definition for counting HST that OE used for
inspectors.
The national completion rate for HST is one hundred
seventeen (171) or 74%. The completion rates range from a high,
of 100% to a low of 50%.
Figure 16 on the following page shows that Region VI I I and
NEIC report 100% rates of completion for HST. Four other Regions
(Regions II, V, VI, and X) are above the national rate, while the
completion rates of Regions I and V equal the national rate.
Four organizations (Regions IV, VII, IX and HQ) are balflw. the
national rate with Region IV at 48% and HQ at 50%. One program
-------
26
within HQ accounts for the low HQ rate (Air Mobile sources),
whereas the rates of completion for the other two HQ programs are
at 100%.
2. Baaic Training (Figure 17)
a. Definition of Completion
The definition in the National Survey is the same as for
inspectors.
Figure 16
110*
% SUPERVISORS COMPLETING H&S TRAINING
Qtan-CHCL* (My - 171)
100* -
90* -
v
2M -
101 -
OX
13
I
\
I I
I
t»
I
ia
to
It
16
I
12
1
I i
W-t
n-7 *-* it-* n-to
Figure 17
% SUPERVISORS COMPLETING BASIC TRAINING
100* -
90S •
m-
70*-
40X-
3D* -
XX •
tox -
i
^
24
I
2*
I
U
i
i
12
I
t2
!
]
12
I
1ft
i
13
H-1 M-2 «-3
M-7
N-tO
-------
27
b.
The national rate for Basic Training completed by
supervisors is one hundred eighty-four (184) or 80%. The
completion rates range from a high of 100% to a low of 60%.
Region VIII with 6 supervisors is the only Region reporting 100%
completion of training. Five organizations are above the
national rate (Regions I, II, III, IV and HQ). Five
organizations are below the national rate including Regions V,
VI, IX, X and NEIC.
-------
28
VII. ORGANIZATIONAL HIGHLIGHTS
Table 5 below symbolizes where each organization stands
relative to the national rate of completion for Health and Safety
Training and for Basic Training for inspectors and for super-
visors. Each organization's completion rate can be characterized
in one of five ways as follows: "100%", "above", "equal to",
"below" or " 20% or less".
Table 5.
Regional Rates of Completion Compared to National Rates for
Inspectors and First-Line Supervisors7
Inspectors Supervisors
Region/ Types of Training Type of Training
Organization H&S Basic H&S Basic
(Nat'l Rate) 83% 89% 74% 80%
I -I- + = +
II + + + +
III - +
IV - -I- +
V ,+ - +
VI + + -
VII - -
VIII + + ++ ++
IX -I- + -
X + ++ + -
NEIC + ++
(HQTRS): (-) (+) (-) ( + )
(Air-Mobile) — + - +
(Air-Stat) ++ ++ ++ ++
(Pest/Tox) - ++ ++ ++
1. Region I: Region I's rates of completion are above the
national rates for BT, both for inspectors and for supervisors.
For HST, the inspectors' rate is above that national rate and the
'The symbols on in Table 5 mean the following: (++) the
rate is 100%; (+) the rate is above the national; (=) the rate
equals the national rate; (-) the rate is below the national
rate; or (—) the rate is 20% or less of the national rate.
Organizations within plus or minus 3% of the national rate are
counted as "equal" to the national rate.
-------
29
supervisor's rate equals the national rate.
2. Region i;r; Region II is one of two regions that
reported completion rates above the national rates for both
categories of training and both categories of personnel. These
rates are among the best in the report.
3. Region III: Region III reports mixed rates. For
inspectors, the completion rate for HST is below
the national, and the rate for BT equals the national rate.
For supervisors, the Region reported the opposite; the rate for
HST equals the national rate, but the BT rate is above the
national rate.
4. Region IV: Region IV's completion rates are mixed.
For inspectors and supervisors, the rates for HST are below the
national rate, but the rate for BT is above the national rate for
both groups.
5. Region V; Region V's rates of completion are also
mixed. For inspectors and supervisors, the rates for HST are
above the national rates, whereas the rates for BT are below the
national rate.
6. Region VI; For inspectors, the completion rate for HST
is above the national rate, and the rate for BT equals the
national. The rates for supervisors are mixed, with HST above
the national rate and BT below the national rate.
7. Region VII; All completion rates for Hst and BT are
below the national rate with one exception. The completion rate
by supervisors for BT equals the national rate.
8. Region VIII; The rates of completion by inspectors for
HST and BT are above the national rates. And for supervisors,
the rates for HST are BT are 100%.
9. Region IXt For inspectors, the completion rates for
HST and BT are above the national rates. For supervisors, both
rates are below the national rates.
10. Region X; For inspectors, the HST rate is above the
national rate and the rate for BT is at 100%. For supervisors,
the HST rate is above the national rate, whereas the BT rate is
below the national rate.
11. HEI£: NEIC reported mixed rates of completion
For inspectors the HST is above the national rate, and is at 100%
for supervisors. The BT rate is 100% for inspectors, but is
below the national rate for supervisors.
12. HQTRS; Three programs have inspectors based in
Headquarters. The Air Stationary Sources reported 100%
completion for all categories. Pesticides and Toxics reported
100% completion in all categories except for HST by inspectors
-------
30
which is below the national rate. The rates for Air Mobile
Sources are mixed with HST being less than 20% for inspectors and
below the national rate for supervisors. For BT, the rates are
above the national for inspectors and for supervisors.
B. Frequency of Regional Rates Above the National Rates:
nsectors and Suervisors
Comparison of rates of completion of training across
organizations can be misleading because of the wide difference in
numbers of inspectors and supervisors. However, an overall
measure of accomplishments with inspector and supervisor training
is the frequency that an organization had rates equal (=) to or
above (+) the national rate. Table 6 below shows the assignment
of each organization to one of three groups using a frequency
analysis.
Table 6
Organizations Grouped by Frequency of Completion Rates
Above the National Rates (Non-CERCLA)
Inspectors Supervisors
Region/ Types of Training Type of Training
Organization H&S Basic. H&S Basic
(Nat'l Rate) 83% 89% 74% 80%
1. Group 1 - Very Good; Organizations with pluses (+) in
three or four categories and no minuses (-).
Air-Stat ++ ++ ++ ++
VIII + + ++ ++
II + + + +
I -i- -i- + •
2. Group 2 - Mixed Results; Organizations with pluses (+)
and/or equals (=) in at least two categories, and only
one minus (-).
Pest/Tox - ++ ++ ++
X + ++ +
VI + +
III - . -. - +
3. Group 3 - Very Mixed Results; Organizations with at
least two minuses (-).
NEIC + ++
IV + +
v + +
IX + +
Air-Mobile — + +
VII - -
-------
31
In Table 6, four organization are in Group l - Very Good;
another four are in Group 2 - Mixed Results; and the remaining
six are in Group 3 - Very Nixed Results. No particular pattern
of completion rates appears to hold o the basis of size of the
organization. For example, Group 1 has two or the larger
organizations and two of the smaller organizations. Groups 2
and 3 are generally a mix larger and medium sized organizations.
Group 3 also has two of the smaller organizations (NEIC and Air
Mobile Sources)
C.
CERCLA Hiahliahts Reaion bv Reaion
Like Table 5, Table 7 symbolizes where each Region stands
relative to the national rate of completion for Health and Safety
Training and for Basic Training for OSCs and RPMs. Each Region's
completion rate can be characterized in one of three ways as
follows: "above", "equal to", or "below".
Most Regions have very mixed results, with only two Regions
(Region III and IV) reporting completion rates above the national
rates both for HST and BT. No Regions reported 100% completion
for either type of training and none reported less than 45% for
either type.
1. Region I; The rate for HST equals the national rate and
the rate for BT is below the national rate.
2. Region II; Both rates equal the national rates.
3. Region III; The rates for both HST and BT are above the
national rates.
4. Region IV; The rates for both HST and BT are above the
national rates and these are the highest reported for CERCLA
personnel.
5. Region V; The rate for HST is above the national rate
and the rate for BT equals the national.
6. Region VI; Both rates equal the national rates.
7. Region VII; The rate for HST is below the national rate
while the rate for BT equals the national.
8. Region VIII; Both rates equal the national rates.
9. Region IX; Both rates are below the national rates.
10. Region X; Both rates are below the national rates and
these are the lowest reported for CERCLA personnel.
-------
32
Table 7.
Regional Rates of Completion Compared to National
Rates for OSCs and RPMs*
OSCs/RPMs
Region/ Types of Training
Organ i z at i on H&S Basic
(Nat'l Rate) (58%) (61%)
I =
II =
III + +
IV + +
V +
VI =
VII
VIII
IX -
X • -
D. Frequency of Regional Rates Above the National Rates:
CERCIA OSCs and RPMs
Comparison of rates of completion of training across Regions
can be misleading because of the difference in numbers of OSCs
and RPMs. However, an overall measure of accomplishments with
OSC/RPM training is the frequency that an organization had rates
above (+) the national rate. Table 8, below, shows the
assignment of each Region to one of three groups using a
frequency analysis. Given that the national training rates for
CERCLA OSCs/RPMs are generally 20% lower than for Non-CERCLA
personnel, the categories used to group Regions in Table 8 are
based on different criteria than the three categories used in
Table 6. The highest rated category in Table 8 is entitled,
Fair; in contrast the highest rated category in Table 6 is Very
Good. Region IV has the highest reported rates both for Health
and Safety and for Basic Training.
In Table 8, two Regions are in Group 1 - Fair; another four
are in Group 2 - Mixed Results; and the remaining four are in
Group 3 - Very Mixed Results. No particular pattern of
completion rates appears to hold on the basis of size of the
organization. For example, Group 1 has two of the larger
organizations. Groups 2 and 3 are generally a mix of larger and
medium sized and smaller organizations. Also in Groups 2 and 3,
•The symbols in Table 6 mean the following: ( + ) the rate is
above the national; (=) the rate equals the national rate; or (-)
the rate is below the national rate. Organizations within plus
or minus 3% of the national rate are counted as "equal" to the
national rate.
-------
33
there is no particular pattern related to the type of training—
HST or BT. Several organizations appear to have lower rates for
HST, while other organizations have lower rates for BT.
Table 8.
Regions Grouped by Frequency of Completion Rates
Above the National Rates for OSCs and RPNs
OSCs/RPMs
Region/ Types of Training
Organization H&S Basic
(Nat'l Rate) (58%) (61%)
1. Group 1 - Fair; Regions with two pluses (+).
Ill + +
IV + +
2. Group 2 - Mixed Results: Regions with one plus (+)
or equals (=); or two equals (=).
II =
V + = -
VI • =
VIII
3. Group 3 - Very Mixed Results; Regions with one or
two minuses (-).
I =
VII
IX - -
X -
-------
34
VIII. CONCLUSIQMS
A. Comparison of National Training Rates in 1992
to National Rates in 1990
In 1989-90, OE worked with the Regions and Headquarters
Compliance Programs to conduct a similar survey of the status of
training under EPA order 3500.1. Although the universe of
inspectors was not measured in the identical way to the universe
in this report, comparisons between the national rates of
training are possible. This section of the report briefly
compares the training rates found for Non-CERCLA inspectors and
supervisors in the National Survey with those reported for
"experienced" personnel in these two categories in the Report on
the Regional Status of Compliance Inspector Training (October
1990). (See Appendix C for a list of this and other training
reports and how to request a copies.)
Table 9.
Comparison of National Rates for Inspectors
in 1990 with Rates in 1992
Type of Training 1990 1992
Health and Safety 60% 83%
Basic 50% 89%
This comparison shows that EPA has made considerable
additional progress in training inspectors in HST and BT during
the two and on half years since OE collected data for the earlier
report.
The comparison for supervisors shows similar proportionate
increases, but the national completion rates still remain below
the rates reported for inspectors. For both groups the greatest
increases have been in the completion of Basic Training, up 39%
in the case of inspectors and up 34% in the case of supervisors
Table 10.
Comparison of National Rates for Supervisors
in 1990 with Rates in 1992
Type of Training JL22P. 1222
Health and Safety 69% 74%
Basic 46% 80%
B. Inspector Training M/?gd? (Non-CKRCIA Inspectors)
This section of the report examines the distribution of Non-
CERCLA inspectors who still needed to complete Health and Safety
-------
35
and/or Basic Training as of the end of 1992. The purpose is to
show which organizations have the most work remaining to meet or
exceed the national rates of training for 1992. These numbers
may have increased or decreased since December 1992, when the
information for this report was submitted, as a result of
turnover or completion of training since January 1993.
1 . Health and Safety Training N^ed.5 ( Non— CERCLA Inspectors )
Two hundred fifteen (215) inspectors still need to complete
Health and Safety Training. About sixty-five percent (65%) or
146 inspectors of that total are concentrated in four organiza-
tions as shown in Table 11. Four other organizations have
between 10 and 15 to train, and another five organizations have
6 or fewer to train in HST.
Table 11.
Health and Safety Training Needs
(Non-CERCLA Total = 215)
Selected Training
Organizations
Region III 44
Region IV 39
Region VII 29
HQ Air Mobile 34
Subtotal= 146
Because Health and Safety Training includes an annual
refresher requirement, the magnitude of the on-going need to
training is far greater than the total suggested above.
Essentially, there is an annual refresher requirement on 1,960
inspectors, including CERCLA OSCs and RPMs. The size of the
affected population has important implications for the structure
and delivery of HST.
2. Basic Training Meeds (Non-CERCIA Inspectors)
One hundred thirty-six (136) inspectors still need to
complete Basic Training. Sixty-five percent (65%) or 89
inspectors are concentrated in four organizations, while eight
other organizations have 11 or fewer inspectors to train in BT.
As currently written in EPA Order 3500.1, Basic Training is
a one-time requirement; there is no requirement for refresher
training in 3500.1, only a recommendation for refresher training.
This means that the future training burden under the existing
Order will continue to shrink, and the number of inspectors to be
trained will depend largely on turnover rates in the different
organiza- tions. This much smaller population for BT poses a
very different set of issues for the structure and delivery of
Basic Training than for Health and Safety Training for
inspectors.
-------
36
Table 12
Basic Training Needs
(Non-CERCLA Total =136)
Selected Training
Organi zations Needs
Region III 24
Region V 26
Region VI 17
Region VII 22
Subtotal= 136
C. Supervisor Training Needs (Non-CERCLA Supervisors)
Because of the important responsibilities of first-line
supervisors both in completing training and in overseeing the
training of the inspectors whom they supervise, it is critical
that new supervisors in particular complete training and know all
of the training requirements under EPA Order 3500.1. Although
the absolute number of supervisors remaining to be trained is
much smaller than the number of inspectors, their pivotal role in
the somewhat fragmented system of training makes their completion
of training key to continued successful implementation of 3500.1.
1. Healtto and Safety Training Needs (Non-CERCLA
Supervisors )
sixty (60) supervisors still need to complete Health and
Safety Training. About sixty percent (60%) or 35 supervisors of
that total are located in four organizations as shown in Table
13. Six other organizations have 5 or fewer supervisors to train
in HST.
Table 13.
Health and Safety Training Needs
(Non-CERCLA Total = 60)
Selected Training
Organi zations Needs
Region III 9
Region IV 13
Region IX 6
HQ 7
Subtotal* 35
Again, because HST includes an annual refresher requirement,
the magnitude of the on-going need to training is greater than
the total suggested above. Depending on the structure of the
first-line supervisor's job, HST requirements may not be
applicable. However, for purposes of this report, OE has assumed
that HST is applicable to all. Therefore, in addition to the HST
requirement for 1,960 inspectors, OE assumes an annual refresher
-------
37
requirement that most likely will apply to all 231 supervisors.
The combined total individuals needing HST annually will be
2,191.
2. Basic Training M?*^s (Non-CERCIA Supervisors)
Forty-seven (47) supervisors still need to complete Basic
Training. Sixty-five percent (65%) or 31 supervisors are
concentrated in five organizations, while six other organizations
have 4 or fewer supervisors to train in BT.
Table 14.
Basic Training Needs
(Non-CERCIA Total= 47)
Selected Training
Organ! zations Needs
Region V 7
Region VI 8
Region IX 5
Region X 5
NEIC 6
Subtotal^ 31
Because there is no refresher requirements for Basic
Training for supervisors under EPA Order 3500.1, the future
training burden will continue to shrink. The number of
supervisors to be trained will depend largely on turnover rates
in the different organiza- tions. Even when combined with the
population of inspectors (136) still needing to be trained in BT,
the overall population for BT training (183) is much smaller than
for HST. This fact poses a very different set of issues for the
future of Basic Training. These and other issues are discussed
in the final chapter of the report.
D. . Estimated F^rtm*** Training Needs (1993 and Beyond)
Table 15 summarizes the training needs remaining from 1992
and estimated for 1993, both for inspectors and for supervisors.
The estimates for 1993 are assume a turnover rate of 15% for
inspectors and 11% for supervisors. These assumptions represent
the average of three years (1990-1992) of turnover rates
calculated nationally. (Refer to graphs and analysis pertaining
to the "year of assignment to current duties" found in Parts IV
and VI.
1 . Health flfld. Safety Training Needs ReMai" a. IfBriS
Constant
Because of the requirement for annual refresher training,
the needs for HST are going to remain constant, or they will grow
if the total universe of inspectors grows over time.
-------
38
Table 15.
Estimated Future Training Needs in 1993
Type of Training 1992 1993
Health & Safety
(Inspectors & OSCs/RPMs) 215 1,960
(Supervisors) 60 231
HST Total= 275 2,191
Basic
(Inspectors & OSCs/RPMs) 136 294
(Supervisors) 47 25
BT Total= 183 319
2. Basic Training Needs Shrink to A Saaller Steady-Statq
In contrast, because BT is a one time requirement, the needs
for BT will shrink to the level generated by annual turnover
rates. Depending on turnover rates in each Region, this level
could rise or fall but will probably remain fairly steady, within
the several hundreds, unless EPA receives major new programs and
resources with which to expand the universe of inspectors. This
prospect is highly unlikely for the next several years.
The large difference in the size of the future populations
needing HST and BT suggest different approaches to the future
design and delivery of these two types of training. Part IX of
this report identifies these issues.
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39
IX. INSPECTOR TRAINING FOR THE FUTURE: ISSUES/KEEPS
Institutionalization of training at EPA is a difficult task
in general, and is exceedingly complex for the universe of
compliance inspectors and supervisors spread across 19 programs
and 14 organizations. Responsibility for training development,
delivery and tracking adds many more organizations in HQ and the
Regions to the list of those responsible. EPA is at a turning
point in the implementation of EPA Order 3500.1. Some aspects of
the Inspector Training Program have been institutionalized in
some programs and regions, but many others have not. This
section of the report identifies issues EPA needs to resolve to
place the Inspector Training Program on a secure footing for the
future. The issues are organized in four areas as follows:
direction and priority for supervisor training; meeting future
training needs for HST; meeting future training needs for BT; and
improving record keeping and tracking of training.
A. Direction and Priority of Supervisor Training
Under 35Q0.1
Training rates for supervisors have remained lower than for
inspectors. Common reasons for this include: the length of the.
Basic Training Course; the decline in frequency of regional
course offerings since late 1991 to one or two times per year
instead of 3 or 4 times per year. In an effort to meet the
requirement, Regions have responded in different ways. The
primary one being to offer more flexibility to supervisors in how
they "satisfy" the requirement, such as Region X developing a one
day course for supervisors.
Yet first-line supervisors are pivotal in securing required
training for the employees that they supervise. Although about
50% of supervisors were assigned to their current duties prior to
1988, and might be assumed to have a fairly good understanding of
3500.1, of the other 50%, about one tenth were assigned in 1991
and 1992. In some Regions, the percentage of supervisors
assigned since 1991 is much higher than this. Continued
leadership by supervisors in securing required training for
themselves and their inspectors is important to continued
successful implementation of 3500.1. Although their greatest
impact is in planning for and securing PSMT, the subject of a
second report, their role in securing HST and BT is also
important.
Issues include the following:
Issue 1: Knowledge of and support for the requirements under
3500.I/ especially among new supervisors, and other
levels of inspection program management.
Issue 2: Future requirement for Basic Training for supervisors.
B. Pufoi^e of Health and Safety Training
Aware of the types of problems Regions and HQ are facing in
meeting the annual refresher requirements, the Safety, Health and
Environmental Management Division (SHEMD) of Office of
-------
40
Administration and Resources Management (OARM) worked with Region
VII on a major Agency-wide evaluation of Health and Safety
Training in 1992. Improving Health and Safety Training in EPA
Regional Offices ( Final Report on the Region VII Health and
Safety Training Project^ . August 1992, sought ways to improve the
"efficiency and effectiveness" of HST.
With the support of SHEMD, Region VII extended the scope of
its original evaluation to include all Regional Offices, and to
address the training needs of field and laboratory personnel.
Compliance inspectors are a large subset (1,960) of the "field
personnel" described in the report. The report offers a detailed
statement of needs and proposed a "Health and Safety Curriculum"
for field personnel (Appendix C to that report). "Recommended
Components of Annual Refresher Training for Field Personnel , "
(pages 40-45) included the following: Program Review/Course
Selection; Self-Study of Selected Courses; Specialized Hands-On
Instruction; Recertification Quiz; Job Peer Group Discussion.
For copies of this report, and/or learning how and when the
recommendations are being implemented nationally, contact Jerry
Oakley, OARM, (202) 260-1287.
C. ygfofli^g of Basic Training
1. Current Situation
This section summarizes the general situation with delivery
of the Basic Training course and identifies key issues for the
future of the requirement for BT under 3500.1. Key is where the
responsibility for delivery will be placed in the future.
a. Shrinking Population. Dispersed in Place and Tine
Given that the bulk of inspectors (about 90%) and
supervisors (about 80%) have completed Basic Training, the future
EPA population for BT will shrink to a "steady-state", probably
in the several hundreds annually, unless EPA expands its
inspection programs under new legislation or with additional
resources for existing programs. Both prospects are unlikely.
The turnover rates vary significantly from Region to Region.
The smaller the number, the less likely the Region will be able
to justify organizing a classroom- type course, using the variety
of in-house staff that the Basic Training course demands. Also
the hiring or the assignment to inspection duties are
unpredictable during the year. As a result, inspectors and
supervisors needing to complete training are "dispersed in place
and time." These two factors make meeting their training needs
in a timely and efficient way a real challenge. This situation
points to the need for shared or joint offerings of the course
between Regions or Regions and HQ.
b. Decline in Frequency of Course Offerings
Course offerings using in-house instructors in the Regions
have declined from 3-4 times per year in larger Regions to 0-1
times per year. This trend will continue. As a result,
-------
41
inspectors may be forced to wait 6 months to 1 year before taking
the course. Because 3500.1 requires completion of this course
before "leading" or "independently conducting" an inspection, the
lack of a this course would prevent the inspector from
functioning as a "lead inspector." This situation hampers
Regional inspection programs and is unacceptable to most Regions.,
Pressures are growing to allow inspectors to go into the field
and to conduct inspections independently without taking the
course—an important source of preparation for field work.
c. Outdated Materials
The student textbook and instructors manual were issued in
February 1989. They have not been updated since that time,
however, they have been used to develop other EPA training
courses such as NETI's Basic Enforcement Course. In the four
years since 1989, of twenty four separate topics, a few
pertaining to legislation and organization structures have become
very outdated. Agency-wide priorities such as incorporating a
multi-media perspective and pollution prevention into compliance
monitoring and enforcement are mentioned but do not reflect
current Agency policies and practices. The majority of chapters
are not "out of date," but they could be improved by changes in
the layout and design of the text, the choice of supporting
materials and visual aids. Any changes besides factually
updating legislation and organization should be tied to decisions
on the future approach to delivery of the course.
Issues include the following:
Issue 1: Future requirement for Basic Training for inspectors.
Issue 2: Currentness and relevance of Basic Training materials
for the "Fundamentals of Environmental Compliance
Monitoring Inspections" Course).
Issue 3: Ability of the existing instruction method (classroom
lecture and exercises) to meet future needs.
Issue 4: Delivery system/structure/responsibilities to meet
future needs.
D. Future, of Record Keeping and National and Regional
Reporting
PART II., METHODOLOGY AND DATA QUALITY, outlined the
underlying problems in collecting and analyzing the information
for this National Inspector/Supervisor Training Survey.
Deficiencies exist in record keeping and the ability to track
accomplishments. Only three Regions had some type of ongoing
record keeping system in place that combined information on all
aspects of required training in one system. Without this type of
system that is kept current, there appears to be little ongoing
effort to keep the universe of inspectors up to date, and to
identify and act on their training needs under 3500.1.
Responsibility for these actions is diffused among all the
Regional line-program managers. The only Regions that have
tracking systems in place are those Regions that clearly assigned
overall responsibility to one individual or organization for the
entire Region. Without a specific counterpart to the HQ Office
-------
42
of Enforcement in every Region, the assignment for tracking has
usually been placed outside the enforcement program structure in
the Region, with varying results.
Issue 1: Relative importance of tracking training v.
tracking other enforcement program activities.
Issue 2: Need for and frequency of future National and/or
Regional reports on the status of inspector training.
Issue 3: Sanctions for non-compliance with EPA Order 3500.1
status of inspector training.
OE will revise these issues based on review by the Regions
and Headquarters Compliance Programs and will work with the
Inspector Training Advisory Board (ITAB) to develop options and
recommendations to address these issues. These will be in the
form of a set of issue papers to be prepared for discussion with
the ITAB. Decisions on these issues will be reflected in
revisions to EPA Order 3500.1. Decisions concerning the future
Program-Specific Minimum Training will also be addressed in the
revised Order as outlined in the section below.
E. Next Steps
OE is working with the Compliance Program Offices to re-
analyze and re-interpret the National Survey on a program-by-
program basis. OE will issue a second report containing an
Agency-wide summary of all national programs. That report will
quantify for each of 19 programs, the universe of inspectors
assigned to each of program; how many inspectors completed PSMT;
and how many completed all requirements under 3500.1.
In the 1990 reports on training, completion rates for PSMT
were the lowest (25%-30% nationally) for all categories of
personnel. Lack of completion of PSMT was the most common reason
that so few inspectors or supervisors had completed all types of
training required under 3500.1. The report will also identify
issues concerning the future of Program-Specific Minimum
Training. Again, OE will revise these issues based on review by
the Regions and Headquarters Compliance Programs and will work
with the Inspector Training Advisory Board (ITAB) to develop
options and recommendations to address these issues. These will
be in the form of a second set of issue papers for discussion
with the ITAB. Decisions on these issues will be reflected in
revisions to EPA Order 3500.1.
For additional copies of this report, please contact:
Rebecca A. (Becky) Barclay
Program Analyst
Office of Enforcement (LE-133)
401 M Street, S.W.
Washington, D.C. 20460
Direct Line: (202) 484-5894; Voice Mail Only: (202) 260-7116;
Facsimile: (202) 260-7553.
-------
APPENDIX B
STATUS OF CERCLA STAFF COMPLIANCE
WITH EPA ORDER 3500.1
Prepared
by
CERCLA Division
Office of Waste Programs Enforcement
Office of Solid Waste and Emergency Response
-------
STATUS OF CZBCLA STAFF COMPLIANCE WITH KPA ORDER 3200.1
I. Introduction
•*
CERCIA has tied fulfillment of EPA Order 3300.1'a training
requirements for inspectors/invent 1 gators into its program-specific
initiative, the On-Scant Coordinator (OSC)/Remedial Project Manager
(RPH) support Program. Two components of this program, 1) th«
CZRCIA Education Cantor (and its predecessor, the osc/RPM Basic
Training Academy) and 2) the Structured Training and Evaluation
Program (STEP} are directly linked to tho requirements for training
and granting except ions contained in the Ordsr.
The attached graphs and table represent the muter and per
cent of CERCIA staff who have aet the Order's requirements either
through attending the designated training or being excepted via
STEP.
II. Data Source and Quality
The data on the current CERCIA workforce was obtained from
EPA's national database, EPAYft. The pertinent information from
EPAYs is regularly downloaded into a national osc/RPK-only database
that has been maintained for several years by the Technology
Innovation Office in Headquarters to track training, information
from CBC course participant list* And STEP classifications is then
manually entered into the database.
Because of problems with the Regional coding of personnel
actions to specifically flag QSCs/RPMs in EPAY3 and incomplete
course attendance lists, we hove had trouble maintaining accurate
information oa the universe of oses/RPnm and their fulfillment of
required training. The information presented on the attachments
results from a fairly extensive asnn«] QA/OjC of the data, but we
recognise that it may still not be completely accurate.
It should be noted that the tracking system does not have
information on first-line supervisors of OSCs/ftPMs. Therefore,
CZRCIA can not report on national compliance for this group.
III.
At the end of 1950, approximately 83% of all new ancui hires
covered by the order had complied with its training requirements.
However, with the transition from the Basic Training Academy to the
CZRCIA Education center and the delay in offering new courses in
the CEC format, the compliance rate dropped, currently, »l% of
CCRCIA staff, new and experienced, are in compliance with the basic
and program-specific reguirements in the Order.
-------
iv. Health 4 safety
C£RCLA has not tracked national compliance with health and
safety training requirements since the Baoio Training Acadexy ended
in 1991. The CEC does not offer health and Miifety as part of its
curriculum. Most of th« Ragiona track their staff's oonplianc*
with tha required health and safety basic training and annual
rcfrashsr training but tnore i« no longer a central national
reporting mechanism.
E'd NOISIAIQ iN3433dOJN3 tTDiQD »2:0T £6, 01
-------
Region
1
2
3
4
5
6
7
8
9
10
Totals
tfRPMs
45
84
60
51
77
40
33
49
70
47
556
it OSCs
12
32
22
22
21
13
15
9
8
9
163
Total
57
116
82
73
98
53
48
58
78
56
719
Completed
Enf. Training
0
1
2
5
. 2
1
2
1
6
0
20
Attended
SF Academy
22
48
34
46
51
17
13
28
33
14
306
Master or
Advanced
10
23
19
6
10
13
13
5
2
13
114
Total Meeting
Requirements
32
72
55
57
63
31
28
34
41
27
440
% Meeting
Requirements
56.14%
62.07%
67.07%
78.08%
64.29%
58.49%
58.33%
58.62%
52.56%
48.21%
61.20%
Number of OSCs and RPMs based on Regional mailing list updated January 1993 (For Regions 2 and 5 only June 1992 data were
available.
Those designated as completing Enforcement Training attended the CEC Fundamentals of Superftind Course and either the four-day
Enforcement Process course, or the Enforcement Process Videocourse and a two-day Negotiations Skills Workshop (for OSCs, only the
Fundamentals and two-day Negotiations training are required)
OSCs and RPMs designated as Master or Advanced Level in the Structured Training and Evaluation Program (STEP) are exempted
from the enforcement training requirements because of experience level and/or previous training (1991 STEP levels were used in the
analysis as no more current data are available).
-------
Percent of OSCs/RPMs Who Have Met
Enforcement Training Requirements
(0
5
Q.
CC.
70
o
CO
o
"CO
=*=»
o
c
o
o
Attended New Enforcement Training
% Requirement Waived due to Experience
% Attended Superfund Academy
-------
Total OSCs and RPMs per Region and Those Meeting
Enforcement Training Requirements
120
Q_
DC
«>
O
0)
O
Total OSCs/RPMs
OSCs/RPMs Meeting Requirements
-------
APPENDIX C
1990 INSPECTOR TRAINING REPORTS
Reports prepared by the Office of Enforcement, USEPA, on
inspector training in 1989-90 include the following:
Building the Enforcement Infrastructure: Compliance Inspector
Training (October 1990) (Analysis program-by-program)
Report on the Regional Status of Compliance Inspector Training
(October 1990) (Analysis a region-by region)
Status of Training of Multi-Program Inspectors in the ESDs and at
NEIC (December 1990) (Analysis of inspector in these
organizations with two or more program assignments.)
Other reference reports:
Inspector Profile (May 1987) (Prepared by the ARA for Planning for
Management in Region 2 for the Agency-Wide Work Group on Inspector
Training and Development)
All reports are available from the following location:
Compliance Policy and Planning Branch
Office of Enforcement (LE-133)
USEPA
401 M Street, sw
Washington, D.C. 20460
For information, call (202) 260-7550,
or fax request to (202) 260-7553
-------
APPENDIX D
SPREADSHEET SUMMARIES
OE arrayed in information from the National Inspector/
Supervisor Training Survey and the CERCLA database into a
spreaDsheet format using LOTUS123 software. Tables and graphs in
the report are derived from these spreadsheets.
INSPECTORS (CERCLA AND NON-CERCLA)
- Number of Individuals
INSPECTORS (NON-CERCLA ONLY)
- Training Status
- Year of Assignment to Current Duties
CERCLA OSCs and RPMs
- Training Status
SUPERVISORS (NON-CERCLA ONLY)
- Training Status
Year of Assignment to Current Duties
-------
SPREADSHEET 1
IHSPECTOIS
BT OKAHXAIIOI (CDCLA AD) IMKKKLA)
CKKLA MOKKKLA
8-1
8-2
8-3
8-4
8-5
8-6
8-7
8-8
8-9
8-10
HEIC
HQTRS
TOTAL
57
116
82
73
98
53
48
58
78
56
0
0
719
127
163
176
108
154
142
95
38
80
57
41
60
1241
TOTAL *
184
279
258
181
252
195
143
96
158
113
41
60
1960
TOTAL
9*
14*
13*
9*
13*
10*
7*
5*
8*
6*
2*
3*
100*
-------
SPREADSHEETS 2 a and 2 b
FEE 10 93
OP LEAD IMSPECP08S (MM-CEKLA)
1
*
ORG
R-l
Jt-2
R-3
R-4
R-5
8-6
R-7
R-8
R-9
8-10
MEIC
HQTBS
TOTAL
ALL HQTKS
AIB-M
AIB-S
PEST/TOX
TOTAL
IMSP
127
163
J.76
108
154
142
95
38
80
57
41
60
1241
60
41
11
8
t MAIL
TOTAL
iO*
13*
14*
9*
12*
11*
8*
3*
6*
5*
3*
5*
100*
5*
31
It
It
COMPLIED COMPLIED COMPLIED COMPLIED
BASIC
117
155
152
101
128
125
73
35
76
57
30
56
1105
56
37
11
8
BASIC
• 92*
95*
86*
94*
83*
88*
77*
92*
95*
100*
73*
93t
89t
93t
90*
loot
loot
HiS
112
152
132
69
143
128
66
35
74
55
37
23
1026
23
7
11
5
HiS
88*
93*
75*
64*
93*
90*
69*
92*
93t
96*
901
38t
83*
38t
17t
loot
63*
PEB 10 93
SOfflAIY riSPBCTOC BT TEA1 Of ASSIQBEW (WKKKLA)
08G
R-l
R-2
B-3
R-4
B-5
8-6
B-7
R-8
8-9
R-10
MEIC
HQTiS
TOTAL
ALL HQT1S
AII-H
AII-S
PEST/TOI
TOTAL
IKSP
127
163
176
108
154
142
95
38
80
57
41
60
1241
60
41
11
8
PSE-1988
49
71
84
14
45
33
15
11
16
36
21
18
413
18
17
0
1
1988
5
6
18
7
13
10
5
2
3
1
1
3
74
3
1
0
2
1989
11
15
24
17
10
5
19
1
14
1
1
10
128
10
4
6
0
1990
27
34
18
17
23
39
19
7
10
5
2
9
210
9
5
2
2
1991
19
29
8
30
26
35
16
3
13
7
8
10
204
10
8
1
1
1992
16
8
24
23
37
20
21
14
24
7
8
10
212
10
6
2
2
-------
SPREADSHEET 3
FEE 10 93 SOfflABY OF CEKLA OSCs AMD RPUs
I \ t \
RPMS OSCs CEKLA
ORG
R-l
R-2
X-3
R-4
R-5
R-6
R-7
R-8
R-9
R-10
TOTAL
INDV
45
34
60
51
77
40
33
49
70
47
556
INDV
12
32
22
22
21
13
15
9
8
9
163
TOTAL
57
116
82
73
98
53
48
58
78
56
719
1 COHPLTED
TOTAL EUP
81
16*
ni
10*
14*
7*
n
8*
11*
81
100*
SP HASTES/ COHPLTED COHPLTED COHPLTED COHPLTED
TMK ACADEMY ADVANCED BASIC BASIC
0
1
2
5
2
1
2
1
6
0
20
22
48
34
46
51
17
13
28
33
14
306
10
23
19
6
10
13
13
5
2
13
114
32
72
55
57
63
31
28
34
41
27
440
56*
62*
67*
78*
64*
58*
58*
59*
53*
48*
61*
HiS
32
71
53
52
61
30
26
33
35
27
420
HiS
56*
61*
65*
71*
62*
57*
54*
57*
45*
48*
58*
-------
SPREADSHEETS 4 a and 4 b
FEB 10 93
TOTAL *
KAIL
ORG SDPV TOTAL
R-l
R-2
R-3
S-4
R-5
R-6
R-7
R-8
R-9
1-10
NEIC
HQTRS
TOTAL
ALL HQTRS
AIR-M
AIR-S
PEST/TOX
18
28
33
25
23
20
15
6
17
20
12
14
231
14
11
1
2
8*
12*
14*
' 11*
10*
9*
6*
3*
7*
9t
5t
6*
100*
6*
5*
0*
1*
SUJOWy OP ALL SUPERVISORS (MOM-CEBCLA)
/ * / J
COMPLIED COMPLIED COMPLIED COMPLIED
BASIC BASIC HiS H4S
16
24
29
23
16
12
12
6
12
15
6
13
184
13
10
1
2
891
86*
88*
92*
701
60*
80*
100*
71*
75*
50*
93*
80*
93*
91*
100*
100*
13
25
24
12
19
16
10
6
11
16
12
7
171
7
4
1
2
72*
89*
73*
48*
83*
80*
67*
100*
65*
80*
100*
50*
74*
50*
36*
100*
100*
FEB 10 93
SUPERVISORS BT YEAS OP ASSIGMMEW (WH-COCLA)
ORG
R-l
R-2
R-3
R-4
R-5
R-6
R-7
R-8
R-9
R-10
MEIC
HQTES
TOTAL
ALL HQTSS
AIR-M
AII-S
PEST/TOI
TOTAL
SOPV
18
28
33
25
23
20
15
6
17
20
12
14
231
loot
14
11
1
2
PH-1988
1988 1989 1990 1991 1992
11
16
21
2
15
7
5
3
7
12
12
7
118
Sit
7
5
0
2
2
0
3
2
1
1
0
0
0
0
0
1
10
4t
1
0
1
0
3
3
3
2
3
0
3
0
0
1
0
2
20
9t
2
2
0
0
1
4
2
5
0
4
5
2
0
1
0
1
25
11*
1
1
0
0
0
2
2
6
2
7
2
0
4
1
0
1
27
12*
1
1
0
0
1
3
2
8
2
1
0
1
6
5
0
2
31
13*
2
2
0
0
------- |