********************************************>««»«*«************* 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 ------- 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. ------- 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. ------- 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. ------- 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) ------- 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) ------- 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. ------- 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). ------- 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. ------- 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 ------- 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. ------- 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 . . . ." ------- 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. ------- 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 ------- 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. ------- Figure 2 10 JDO INSPECTORS BY ORGANIZATION (CEKL* * NW-QBCL* • uao) it-a n-r *-• M-t n-io ------- 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. ------- 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 ------- 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%. ------- 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%. ------- 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. ------- 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 ------- |