Fieldwork Operations
and
Needs In Region III
Strategic Planning and
Management Branch
March 2000
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Fieldwork Operations
and Needs in
EPA, Region ill
Strategic Planning and
Management Branch
March, 2000
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Table of Contents
Title Page
Contents i
Appendices iii
Tables iv
Figures iv
Highlights v
Introduction 1
Methodology 1
Issues for Management Resolution 4
Key Issues 4
Region III Has No Vision for Fieldwork 4
Region III Has No Central Planning for Fieldwork 6
Organizational and Physical Location of Field Staff May Change 7
Communication and Feedback Are Reported to Be Poor 8
Support for Fieldwork Varies Widely 9
Findings and Analysis ..- 10
Region III Has No Vision for Fieldwork 10
Region III Has No Central Planning for Fieldwork 12
Organizational and Physical Location of Field Staff May Change 14
Communication and Feedback Are Reported to Be Poor 16
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Title Page
Support for Fieldwork Varies Widely 17
Summary of Information Sources 19
Program Manager Interviews 20
Types of Fieldwork Needed 21
Resources Available for Fieldwork 27
Safety Training 32
Projecting and Scheduling Fieldwork 32
Quality, Quantity, and Timeliness of Fieldwork 34
Fieldwork Needs in the Next Three to Five Years 35
ESD Interviews 37
Program Field Staff Interviews 41
Environmental Services Division Resource Analysis , 44
Other EPA Regions 48
Headquarters Input -. 49
Interviews with OECA Managers 49
National Training Requirements for Fieldwork 50
Comparison with the ESD Internal Study 51
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Appendices
Appendix A. Project Outline
Appendix B. Study Advisory Committee
Appendix C. Interview Questions
Appendix D. Interviewees
Appendix E. Study Team Members
Appendix F. EPA Order 3500.1
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List of Tables
Title Page
II-l. Definition of "Fieldwork" 2
V-l. Types of Fieldwork Needed 22
V-2. Purposes of Fieldwork 24
V-3. Resources Used to Accomplish Fieldwork 28
V-4. Specific Fieldwork Resources Reported by Program 30
V-5. BSD Inspector Training 40
V-6. BSD FTE Allocation FY'89 Through FY'98 45
V-7. BSD Inspector Resources FY'90 Through FY'98 47
V-8. Crosswalk of ESD FTE Allocation - FY'98 to FY'99 48
Figures
V-l. Scheduling and Projecting Fieldwork 33
V-2. Time Spent Performing Fieldwork 42
V-3. ESD FTE Allocation (Total) 46
V-4. FTE Allocation for ESD Inspectors 46
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Highlights of the Fieldwork Findings
Region III Has No Vision for Fieldwork
O Region III has several competing visions of the purpose of fieldwork, each defined by the needs
of a program.
O A new approach to inspections, focusing on process evaluations, is emerging and will have a
significant impact on fieldwork needs. This new approach requires a different skill mix than
traditional inspections.
O The States have taken the lead in enforcement and fieldwork. EPA provides a complementing or
supporting role.
Region III Has No Central Planning for Fieldwork
O There is no centralized, Region-wide planning for fieldwork. Four different approaches to
scheduling fieldwork are used by the programs.
O BSD has adopted a consolidated workplan with the programs to address past problems of
scheduling fieldwork and sample analysis.
O The slow delivery of inspection lists to ESD makes it difficult for the inspectors plan and
schedule fieldwork
Organizational and Physical Location of Field Staff May Change
O Most managers rely on their own staff to meet their fieldwork needs. About 150 program staff
devote 75 FTE to fieldwork.
O ESD has 7 inspectors in Ft. Meade; 5 in Wheeling. 8 of the 12 inspectors will be eligible to retire
by 2005.
O The ESD Inspectors are full-time field staff; program staff are not. None of the program field
staff interviewed stated that they spent as much as half their time performing fieldwork.
O The ESD inspectors are the only EPA personnel in the Region who routinely take samples.
O Most program managers stated they were satisfied with the quality, quantity and timeliness of
fieldwork they were receiving from ESD.
Communication and Feedback Are Reported to be Poor
O ESD inspectors feel the programs should provide more detailed objectives for inspections.
O ORC managers expressed concern that inspection reports and samples were "stale" when cases
are prepared,
O Program staff, as the intermediaries between ESD and ORC, have a critical role in the
communication issue.
Support for Fieldwork Varies Widely
O The ESD inspectors reported no issues with equipment or operational funds. Program staff had
issues with operational funds.
O Most program field staff were unsure of programmatic training requirements for inspections.
The ESD inspectors and APD Enforcement staff understood the requirements and had received
the training.
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Fieldwork Operations and Needs
in EPA. Region III
I. Introduction.
In August 1998, Region Ill's senior managers commissioned a comprehensive study of
laboratory and fieldwork functions in the Region. The study was intended to determine what our
needs are now and in the future for those functions to allow the Region to meet all agency
programmatic requirements and Regional workload demands. The Region's deputy directors,
who meet regularly as a team to propose solutions to resource issues and other management
concerns, were asked to conduct the study. Robert Mitkus, Deputy Director of the Office of
Communications and Government Relations (OCGR), was designated the lead deputy director
for the study.
To facilitate work, the study was divided in two: one part for laboratory functions, the
other for fieldwork. The study of laboratory functions was conducted on a Zero-Base Budget
(ZBB) basis with staff support provided by the Strategic Planning and Management Branch
(SPMB). Study findings were presented in March, 1999. Decisions based on the study's
findings have been made and are being implemented in FY 2000.
The fieldwork portion of the study was developed and carried out by SPMB from May
through December'1999. SPMB worked closely with Robert Mitkus, who was overall lead for
both studies, and Elaine Wright, Deputy Director of the Air Protection Division (APD), who
agreed to serve as co-lead for the fieldwork portion of the study. Each division also designated a
senior staff person to serve as an advisor to the study.
The report presented here is the final report of the SPMB study of fieldwork. It is an
interim phase of the whole effort, however, because senior management will make all final
decisions using the analyses and materials provided here.
II. Methodology.
Fieldwork, particularly the performance and organizational location of staff who perform
programmatic inspections of industrial facilities subject to EPA regulations, has been the subject
of several previous studies in Region III dating back 20 years. Staff assigned to the present study
have made a conscious effort to provide continuity with earlier studies. One tangible result is the
definition of fieldwork in Table II-1 on page 2, which follows those used in the 1979 and 1986
studies.
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Table IM. Definition of "Fieldwork."
"Fieldwork" consists of activities performed out of the office for any type of fact-
finding purpose, whether they include sample collection, other environmental data
collection (e.g., ambient and special purpose monitoring), observations relative to facility
operation and waste handling practices, identifying regulatory violations, overseeing site
cleanup, or evidence gathering; etc. Fieldwork in this sense is generally carried out for four
reasons: 1) to ensure that the Federal laws are complied with and to properly document
instances where this is not the case; 2) to provide necessary oversight of the State's field-
related policies, procedures and capabilities; 3) for cleanup of hazardous waste sites; and
4) to maintain a "presence "for the regulated community and to alert it that EPA is carrying
out its regulatory responsibilities. Also included in "fieldwork" is the oversight of that
portion of any contract which is let to perform field work.
Fieldwork includes all of the following EPA activities:
- Statutory Inspections (e.g., RCRA, TSCA/FIFRA, UST);
- Compliance Inspections (all programs);
- Case Development (criminal and civil enforcement programs);
- Emergency Response (oil spills\EPCRA);
- Site Cleanup (CERCLA, RCRA);
- Ambient and Special Purpose Monitoring and Sampling (air and water programs);
- Environmental Assessments (NEPA); and
- Oversight of State Programs (all delegated programs).
All activities conducted in the field are not considered fieldwork for purposes of this
definition. In general, any field visit for the purpose of enabling a program person to better
perform his/her job is not fieldwork. For example, site visits for permit writers to gain
knowledge needed to write a good permit is not considered fieldwork. Visits so that a
program person can become more familiar with a site in relation to an enforcement case or
review of an environmental assessment are also not fieldwork. Some file reviews, such as
those made to target inspections or for case development, are fieldwork. Others are not.
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Coordination of the study was eased by the success of the collaboration between Robert
Mitkus and the SPMB staff in the study of laboratory functions mentioned above. Work on
preparations for the study began as soon as the results of the laboratory study were presented to
senior management.
A workgroup was convened by Stanley L. Laskowski, Director, Environmental Services
Division (BSD), and Samantha Fairchild, Director, Office of Enforcement, Compliance, and
Environmental Justice (OECEJ) to discuss the scope of the study. SPMB prepared a project
outline (Appendix A.) based on the meeting and further discussions with Robert Mitkus. Mr.
Mitkus and SPMB briefed Deputy Regional Administrator Thomas Voltaggio on the approach.
With Mr. Voltaggio's approval, Mr. Mitkus then presented the outline to senior managers.
The Goal of the study was:
Define the program requirements under GPRA for "inspections" and insure the
availability of competent and responsive "inspectors" to meet GPRA goals, Regional
priorities and environmental emergencies.
The "Outcomes for Region III" were:
Create and maintain a core of competent, ready, trained staff for field activities.
Determine appropriate organizational locations and levels of inspector resources.
Meet present and future GPRA requirements.
As mentioned in the Introduction, the Study Advisory Committee (Appendix B.),
consisting of senior staff representatives from each division and office, was formed to provide a
sounding board and source of information to SPMB during the study. The basic informaiion-
gathering device was to interview key managers in the programs who need fieldwork performed
as part of their program operations; staff in ESD who specialize in fieldwork, and their managers;
and program staff who perform fieldwork as a major portion of their jobs. Advisory committee
members were key in identifying the staff who should be interviewed.
More than 70 Region III staff were interviewed in three different phases. In July and
August of 1999,40 managers who were identified by the advisory committee as those who used
fieldwork in their programs were interviewed by SPMB staff. In September, 11 managers and
staff from ESD who provide fieldwork and analytic support to other divisions were interviewed.
Finally, in October, 23 Region III staff members from program divisions and offices who do
fieldwork as part of their regular jobs were interviewed.
In the course of the study, SPMB staff also interviewed personnel involved in fieldwork
in EPA Headquarters and the other nine Regions. ESD resources for fieldwork were analyzed
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for the last eleven fiscal years (1989 through 1999) to identify trends and provide a link with the
previous studies. Finally, study team members analyzed a customer service study of fieldwork
prepared by ESD in 1999 and compared it with the findings of this study. No external parties in
state and local government, or other federal agencies, were interviewed.
The study has been prepared to assist the Region's Senior Leadership as they make the
basic decisions in the project outline. The major issues for management consideration that the
study team discovered are presented in Section III. The study's findings, and a detailed analysis
supporting the findings, are presented in Section IV. A summary of all data and information
collected in the study is contained in Section V.
III. Issues for Management Resolution.
A. Introduction.
The study Outline included an overall goal for the study and a number of related products
and outcomes. The purpose of the formal part of the study was to gather and present information
to the Region's Senior Leadership Team that would allow them to make informed decisions and
policies concerning the future needs of fieldwork in the Region.
The team's analysis of its data and findings, however, revealed that many of the key
decisions involve choosing one of several alternatives. Therefore, key issues have been drafted
to present the critical information in a way that the alternatives can be understood.
B. Key Issues.
1. Region III Has No Vision for Fieldwork.
Region III does not have a common "vision" or purpose for fieldwork. Instead,
there are several competing visions, each defined by the fieldwork needs of a particular program.
The absence of a common vision was important because one of the major outcomes of the study
was to prepare the Region to meet "present and future GPRA requirements" for fieldwork. When
the interviewees were asked about their future needs for fieldwork, some stated that the fieldwork
needed in the future depended on the purpose of the fieldwork, which, in turn, depended on the
objective, or "vision" for fieldwork. Further discussion revealed that, at the present, fieldwork
needs define the vision, not the reverse.
There are three different approaches to fieldwork in the Region, each with a
supporting vision. The problem is that the approaches compete with each other, instead of
accommodating each other, and there is no existing agreement in the Region that allows them to
coexist.
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One approach is based on the assumption that the states are the primary enforcers
of environmental regulations in Region III. In this view, inspections should be used to establish
EPA's presence throughout the Region, not to develop enforcement actions. In this approach,
inspections should be rotated on a schedule that will treat all industrial sectors; all programs; and
all areas of the Region equally. Sources will come to understand that their primary regulators are
state agencies, but that they are liable to random inspection by EPA regardless of their standing
with the state. This should increase voluntary compliance, and, thus, attainment of standards,
without significant expenditure of time in an adversarial process.
The second approach views inspections and inspectors as tools in a federal
enforcement program. Facilities to be inspected should be selected from a list of known or
suspected violators. Inspection results should be examined carefully to uncover all possible
enforcement actions. The key variable is the mechanism used to select, or "target," the facilities
to be inspected, since the actual techniques used by the inspectors are the same for each
approach.
The third approach involves a new way of doing inspections. Historically,
inspections were targeted based on source self-monitoring reports; state enforcement actions;
citizen complaints; and past federal enforcement actions. In recent years, a new approach has
been developed. It started with a national initiative to focus on key industrial sectors. In Region
III, it has been refined into an approach that looks at the source as a whole to discover changes in
operations that violate EPA permitting or regulatory requirements. Changes could be in
processes or in the volume of fuel or raw material used. This approach has been implemented by
the Stationary Source Enforcement Program in APD. It has been used to evaluate individual
facilities and industrial sectors. Both the RCRA Enforcement Program in the Waste and
Chemicals Management Division (WCMD) and the NPDES Permit Enforcement Program in the
Water Protection Division (WPD) indicated that they plan to adopt the program during the next
five years. All three programs emphasized regulating industrial facilities.
If the change from traditional inspections to process-based inspections occurs as
predicted, all three programs also predict that the switch will result in a decrease in the number of
inspections being performed in the Region; an increase in the resources needed for inspections;
and a change in the skill mix needed for inspections. This is because the new type of inspection
is resource intensive, compared to the traditional approach, and relies more heavily on engineers
and scientists, instead of environmental technicians.
Two other programs that foresaw specific fieldwork changes over the next five
years, defined their needs in traditional terms. The Total Maximum Daily Load (TMDL)
program is facing a court-ordered deadline to prepare several hundred new standards by the end
of 2004. The demand for ambient water quality data from the streams subject to the order
exceeds the ability of the states and EPA in monitoring. The Safe Drinking Water Program will
be responsible for direct implementation of eleven new drinking water regulations while the
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states go through the delegation process. The program will need to do traditional inspections and
take samples at facilities during that period which will last for several years.
2. Region III Has No Central Planning for Fieldwork.
At present, there is no Region-wide, centralized planning for fieldwork and no
identifiable GPRA requirements for fieldwork. The lack of GPRA requirements for fieldwork is
similar to the finding in the laboratory portion of the study. It reflects EPA's policy of preparing
agency-wide planning and budget documents in general terms that make it impossible to identify
activity at the Regional, State, or Tribal levels.
There is also no preferred, or common, approach to fieldwork planning on a
program-by-program basis. Instead, four different approaches are used. Some programs include
fieldwork commitments in the Memoranda of Agreement (MOAs) they negotiate with
Headquarters. Some negotiate annual workplans with ESD. A third approach is to schedule
fieldwork only on demand, or on an "as needed" basis. Finally, some programs schedule
fieldwork with the states. The lack of a common approach may reflect the absence of a
discussion of fieldwork in the agency's GPRA planning documents.
The lack of emphasis on planning was also reflected in the managers response to a
question about their present fieldwork needs. They responded in terms of resources they have
available for fieldwork, not the numbers of inspections they would like to have performed.
When asked about changes over the next three-to-five years, they generally said fieldwork would
remain the same, or increase slightly. Some specific changes were cited. One was the need for
more experts to conduct process-based inspections. Another was that process-based inspections
would reduce the number of inspections, but increase the time spent on inspections. A third was
a need for more ambient monitoring data to support special initiatives such as the development of
TMDLs. Increased inspections and sampling will also be needed for direct implementation of
programs such as the 11 new drinking water regulations that Region III will have to implement
until the states complete the delegation process.
The only existing planning effort that could be adopted as a vehicle for centralized
planning for fieldwork at the Regional level is the Region's MO A with the Office of Enforcement
and Compliance Assurance (OECA) for Goal 9. Most fieldwork is part of EPA's enforcement
and compliance program and most fieldwork resources are allocated through Goal 9.
ESD has been working to improve the scheduling of fieldwork by developing
better workplans with Regional programs. Until recently, programs had to enter two agreements
with ESD for fieldwork. One with the Office of Environmental Programs (OEP) for inspections
and one with the Office of Analytical Services and Quality Assurance (OASQA) for the analysis
of samples. This resulted in situations in which samples arrived unexpectedly at the OASQA
and could not be analyzed on schedule.
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Starting in FY'99, OEP has been negotiating one BSD-wide workplan with each
Regional program and then working with OASQA on scheduling samples and analyses. The
new system has worked well internally in BSD. However, there are still problems. From ESD's
point of view, the issue is inadequate advanced planning by the programs. Lists of facilities to be
inspected are delivered late; addresses are out of date; basic information on the scope and
purpose of the inspection is missing; sometimes, there is no notification that a sample is required;
and OASQA is not given enough lead time to prepare to analyze samples. Program issues with
BSD are late delivery of inspection reports and inadequate analytic capacity at OASQA which
results in late delivery of sample analyses.
3. Organizational and Physical Location of Field Staff May Change.
Another outcome of the study was to determine the appropriate level of field staff
needed by the Region and to determine the organizational location of field staff. Currently, the
Region's organization is split into two very different patterns, both in the duties of field staff and
their location in the Region. Most staff doing fieldwork, about 150 EPA staff who devote a total
of 75 FTE to fieldwork and 11 SEEs who are full-time field staff, are employed by programs in
Philadelphia. All of the program staff in Philadelphia have non-fieldwork duties as well as field
responsibilities. Twelve inspectors are full-time field staff and work for BSD. Seven of those
inspectors are assigned to Fort Meade, MD. The other five are located in the Wheeling, WV
field office. There are also two full-time air program case developers who are former BSD
inspectors who are housed in the Wheeling field office.
Organizational location of inspectors should have no bearing on an inspector's
ability to conduct the traditional inspections discussed in the first issue. The targeting question
also concerns the way traditional inspections are scheduled, not the way they are conducted.
The new approach to evaluating and investigating-process changes at facilities
requires different skills than those used for traditional inspections, according to the program
managers who are using the new system. Specifically, there will be a need for more engineers
and scientists. More of the work will be done in the office and less on site at facilities. These
changes in skill mix and the setting for work are additional factors to consider in deciding
whether to locate fieldwork personnel in program offices or traditional field units.
The issue is complicated by an anticipated change in the composition of ESD's
inspector corps. Currently, four of the twelve ESD inspectors are eligible for retirement. By
2005, eight of the twelve will be eligible for retirement. The other four will be eligible to retire
by 2010. The ESD managers and inspectors all pointed out that the implications of a potential
100% turnover in the inspector staff need to be considered carefully.
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If the retirements occur, the change in field personnel would give Regional
management a unique opportunity to consider:
- whether to continue to have a specialized corps of inspectors who are devoted to
fieldwork on a full-time basis;
- whether inspectors should continue to be located in the Wheeling and Ft. Meade
field offices; and
- whether BSD is the proper organization to house and manage the inspectors.
If Regional management decides to continue to have specialized inspectors, then
management will also have to decide how to recruit and train inspectors during the transition.
The ESD inspectors would like to participate in a transition program, but they feel that the best
way to do that would be for the Region to hire new inspectors on a phased basis, so that training
can go on before the retirements begin. The ESD inspectors feel that the benefits of having staff
who specialize in inspections outweigh any negatives in terms of organizational and physical
distance from program managers. Both ESD inspectors and program field staff noted that there
were benefits to joint inspections where ESD inspectors accompanied program field staff on
visits to facilities.
If Regional management decides not to continue to have specialized inspectors,
one area of fieldwork that will require change is in sample-taking during inspections. At the
present, the ESD inspectors take almost all samples at facilities. Fieldwork staff in three
programs said that they had taken samples during FY'99, but two had only taken one sample each
and the third had taken four. The CERCLA Removal and RCRA Enforcement programs said
that they also use contractors to take samples. Several attorneys said that when enforcement
cases go to trial in federal court, the Department of Justice will not introduce samples as
evidence unless they have been taken and analyzed by EPA employees.
Another concern about sampling is the storage of equipment used to take samples.
This'ranges from chemicals used in sampling to heavy equipment such as cylinders of
compressed gases and boats used in the field. Additional space will have to be leased, or current
leases modified, to meet the special needs of the inspectors.
4. Communication and Feedback Are Reported to Be Poor.
Poor communication and lack of feedback were raised as significant problems by
enforcement attorneys and ESD inspectors. The problem seems to reflect the fact that the ESD
inspectors and the attorneys communicate with each other through the program offices.
However, some program field staff also had communication problems. There are several aspects
to this issue.
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First, BSD inspectors said that they rarely get any feedback. They do not know if
the inspection met the expectations of the program, or if a significant compliance action resulted.
Part of this is due to the physical separation of program field staff in Philadelphia and ESD
inspectors in Ft. Meade and Wheeling. There is little opportunity to meet and share information.
On the other hand, some ESD inspectors feel that their location in the field, away from
Philadelphia, has a benefit in that they can travel easily to sites that are a day's travel each way
from Philadelphia. They also feel that they are perceived as "locals" by many of the workers
they deal with, since they are not located in Philadelphia.
Second, poor communication also results in bad inspections. The ESD inspectors
feel that they can conduct any type of inspection that is required, provided that they are properly
briefed by the program. However, they say that the programs frequently do not provide complete
information about the facilities to be inspected. The result is incomplete fieldwork. Both ESD
and program staff reported that inspections were more thorough when ESD inspectors
accompanied program staff on an inspection.
Third, some attorneys reported that they have problems with physical evidence in
some enforcement cases. By the time an attorney is preparing a case for court, the physical
evidence from the inspection is frequently considered out of date, or "stale," but inspectors are
reluctant to reinspect a source on short notice. In most instances, the evidence of a violation
resulted from a carefully planned inspection that included advance notice to the facility so that
the permitted operation could be observed. Without sufficient advance notice and preparation,
inspectors feel that violations may not be able to be documented.
Finally, staff in several programs reported that they received only negative
feedback from attorneys. This included complaints that reports were late, or inadequate, that
samples were missing, or stale, etc.
5. Support for Fieldwork Varies Widely.
There is a measurable difference between the level of support that exists for ESD
inspectors and that for program staff who do fieldwork. ESD inspectors reported no issues or
problems with travel money or equipment. On the other hand, program staff said that lack of
travel money was a significant issue and some had limited operational funds. Part of the problem
may reflect FY'99 budget issues.
Field staff in program offices are also not aware of all training requirements for
fieldwork. There is confusion over whether all staff who need training have received it.
During the course of the interviews of programmatic field staff, several persons
stated that they had not received any formal training, other than safety training, before going into
the field. The study team contacted OECA staff in Headquarters and learned that all training
requirements for fieldwork, including health and safety training, are contained in EPA Order
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3500.1. The Order distinguishes between health and safety training; basic inspector training; and
program-specific training. It requires all three kinds of training for all field staff before they are
allowed to conduct inspections on their own and also requires that first level supervisors of field
staff take the same training.
BSD inspectors were aware of the requirements of the Order and were current in
their training. The only program staff interviewed who were familiar with the Order and said
that they met all relevant requirements were those in APD.
Both program managers and program staff expressed concern that the recent
retirement of the person who had been tracking the safety training status of field staff may result
in some staff missing the annual refresher training in safety: The safety officer in the Office of
Policy and Management has assumed this function and is taking steps to make sure that safety
training is up to schedule for all field staff.
If Regional management keeps a significant part of its fieldwork effort in the
programs, it will have to address the issue of guaranteeing support for field staff. It appears to be
a matter of allocating resources and of coordinating activity to make sure that equipment is
available and that training courses are taken. The issue of storing chemicals, gas cylinders, and
other supplies used in inspections, for field staff who are not located in Wheeling or Ft. Meade
must also be addressed.
IV. Findings and Analysis.
The study team considered a broad range of information. More than 70 Regional
employees were interviewed, along with OECA managers in Headquarters and fieldwork
contacts in other regions. Region III fieldwork studies dating from 1978 through a 1999 ESD
study of customer satisfaction with inspections were reviewed. An analysis was made of ESD
FTE allocations over the past eleven years. Several national publications, including EPA Order
3500.1 on training, were analyzed. A summary of these efforts, outlining the entire study,
follows as Section V. The purpose of this Section is to present the findings and analysis that led
to the issues listed above. The material in this Section is organized to parallel the topics in
Section III.
A. Region III Has No Vision for Fieldwork.
1. Key Findings.
A.I One barrier to cooperation on fieldwork is that there is no common
agreement on the objective of fieldwork or the purpose of inspections. Some see inspections as a
means to uncover violations and support high enforcement numbers. In this approach,
inspections should be targeted to facilities that have a known history of non-compliance. The
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contrasting point of view is that inspections should support compliance in general by making
EPA's presence known throughout the Region.
A.2 The new, process-based, approach to screening facilities which has
emerged in recent years may impact fieldwork in several ways, including changing the skill mix
needed for inspections, the number of inspections performed, and the time spent on each
inspection. Historically, facilities were targeted based on source self-monitoring reports; state
enforcement actions; citizen complaints; and past federal enforcement actions. In recent years, a
new approach has been developed. It started with a national initiative to focus on key industrial
sectors. In Region III, it has been refined into an approach that looks at source records to
determine changes in processes or in the volume of fuel or raw material used to find plants or
sectors that have violated EPA permitting requirements or applicable emission regulations
without violating emission rates. In the next five years, many Regional managers want to expand
on the process-based investigation as the favored approach to fieldwork versus the traditional
inspection. ESD managers agreed that there was merit to this approach.
A.3 The role of the states and state inspectors has changed over time.
ESD and OECA managers feel that the state inspectors are now the experts and that EPA's field
resources supplement them. EPA fieldwork should be used as a tool for state oversight, or to
maintain a federal presence, with two exceptions. EPA should always be prepared to step in at a
state's request, or if there are allegations that a state is ignoring a non-complying source.
2. Analysis.
There is a great deal of misinformation and confusion concerning this issue. Most
managers understood their point of view and defended it, but few had a clear understanding of
the other side. ESD managers felt that the new approach to inspections^ which are more properly
considered evaluations, or investigations, had merit. However, ESD would have to take a very
different approach to fieldwork to support this effort.
The problem of not having a clear vision for fieldwork was raised by some of the
ESD interviewees. One said that since the Region has not clearly defined whether or not
inspections are conducted to find violations, maintain a federal presence, etc., fieldwork could
not be scheduled and prioritized properly. Several inspectors could not identify common
Regional objectives to inspections.
A philosophical factor is whether enforcement cases lead to compliance with
regulations and attainment of standards faster than a compliance-oriented approach. Some feel
that the adversarial relationship of a court case delays compliance.
Both the RCRA Enforcement and Air Enforcement program managers who were
interviewed felt that the change to process-oriented inspections would increase their workload.
(Air currently does the new style inspections, RCRA plans to adopt them in the future.) They
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expect that the number of field inspections will decrease, but the amount of time required to
conduct them will increase compared to FY'99. A new skill mix will also be required for process
inspections. Existing staff will require new training. If and when new staff is hired, the skill mix
is expected to change.
There are two key factors to consider. One is that, in the opinion of ESD and
OECA managers, the states have a much better program than ever before. States are the
dominant force in the field. EPA inspections are secondary. The states emerged as leaders about
ten years ago, but EPA managers have been slow to recognize the change. The other factor is
that the process oriented evaluation of sources requires much less fieldwork than previous
enforcement initiatives. The focus is on violation of permitting requirements such as New
Source Performance Standards, not on violation of emission limits or control equipment failures.
B. Region III Has No Central Planning for Fieldwork.
1. Key Findings.
B.I There is no common approach to fieldwork planning in Region III.
Some programs have fieldwork requirements included in the annual MO As that they negotiate
with Headquarters. Others plan fieldwork at the regional level, either internally in the Regional
Office, or with the States. Finally, some programs do not plan fieldwork at all, but undertake it
on an "as needed" basis.
B.2 ESD is taking steps to revise its scheduling of fieldwork. There were
some problems cited with the ESD workplan process that has traditionally taken place. Until
recently, ESD required two workplans for each program: one for inspections and one for
analytic support. The new management team in ESD has instituted a "one-stop shopping"
approach with one workplan, covering all ESD support to each program, being negotiated. Both
ESD and the program managers reported that the new approach works much better than the old,
although some program managers felt that more time was needed to make sure that the system
really works.
B.3 In spite of ESD's new approach, some problems remain, especially
the slow delivery of inspection lists to ESD. In FY'99, according to ESD managers, no program
submitted their list until after the end of the first quarter. The last list (for RCRA inspections)
was received in April. This has the result of making smooth scheduling and delivery of reports
impossible. In one instance, 24 of 40 RCRA inspection reports were delivered on one day,
instead of 10 each quarter. The program cited this as an instance of poor service by ESD, while
ESD inspectors and managers cited this as an instance when the program's delay meant that ESD
could not schedule work properly during the good weather. ESD inspectors also said that the
inspection lists were not always complete, because special requests, such as sampling, were not
always included in the information received from the programs and because, in some cases, the
facility addresses were inadequate or out of date.
12
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B.4 Headquarters has also been slow in providing targets for TSCA
inspections which are performed by program staff. In FY'99, the list for inspections of PCB
sources did not arrive until the end of the third quarter.
B.5 There are some issues with the way enforcement resources are
allocated to the Region from Headquarters. Enforcement resources that used to be allocated
through the program offices in Headquarters are now pooled and allocated by OECA. There is
no longer any programmatic label to the resources, so the Regions are free to reallocate them as
they see fit. This approach can cause problems. For example, when the CID staff assigned to the
Region asked OECA for resources for analytic support, they were told that any resources
available in Region III to allocate to the regional lab for sample analysis were included in the
overall OECA allocation and should be part of the Region's annual internal resource allocation
process. Since CID is part of Headquarters, this sends a very confusing message.
B.6 The Region's Enforcement MOA with OECA appears to be a ready-
made vehicle for comprehensive fieldwork planning. In spite of the fact that there are some
problems concerning the OECA MOA, it is the most comprehensive planning document for
enforcement in the Region. Since most fieldwork supports enforcement and compliance
activities, the MOA could be used as a vehicle for centralized fieldwork planning.
2. Analysis.
Planning is key to the study's mandate to determine the Region's fieldwork
requirements under the Government Performance and Results Act (GPRA) and to make sure that
future GPRA needs are met. Unfortunately, fieldwork represents activity at a level of detail that
is frequently not included in national plans or Headquarters program guidance.
For example, the agency's Strategic Plan and Annual Performance Plan are both
written to avoid making specific commitments by Regions, States, or tribes identifiable.
Therefore, there are no official GPRA requirements for fieldwork. Some programs put -
inspection commitments in their MOAs, but, as was the case in the laboratory portion of the
study, there is no overall list of requirements for the Region or for States implementing delegated
programs in the Region.
The issues involving ESD workplans with the programs seem to be solving
themselves. ESD management has made a conscious effort to improve service. The issues
involving the lists of facilities to be inspected should be able to be solved through the relevant
managers.
A more fundamental matter for management consideration is to decide if the
Region needs to undertake centralized planning for fieldwork, or if using four separate
approaches works just as well. The OECA MOA was mentioned as a possible vehicle for
centralized planning. It is a possible vehicle, but not an ideal one, since fieldwork can appear in
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any Headquarters MOA. This makes it difficult to use the OECA MOA as a vehicle for
comprehensive fieldwork planning. However, the analysis of ESD resources in the study showed
that the inspector resources came from enforcement (Goal 9). Therefore, it is the only MOA that
could be used. It would have to be adapted to account for fieldwork resources that are allocated
through Goals 1 and 2.
The study asked program managers to discuss present and future fieldwork needs.
Based on the interviews, current needs are being met for the most part. Demand was expressed
in FTE, or staff needs, not in numbers of inspections or number of sources to be inspected.
Future needs were not always stated clearly.
The future needs that were clearly stated were in WPD. There is a need for more
ambient monitoring and sampling in water to support writing of TMDLs to meet a court-ordered
deadline (this would involve Goal 2 resources). There is also a need for field staff to support the
direct implementation of 11 new Drinking Water regulations while the states are going through
the delegation process (both Goals 2 and 9).
Other programs expressed uncertainty or complexity about future needs. For
example, RCRA Enforcement and Stationary Source Enforcement (Air) noted that the change to
process-oriented inspections is expected to result in fewer inspections but also in more resources
being devoted to inspections.
Predictions about the future of the asbestos program were contradictory. Office of
Regional Counsel (ORC) managers were told to expect more complex asbestos cases in the
future. CID was told that asbestos cases would be dropped in favor of more complex cases in
other media in the future. Program managers in WCMD had been told that big changes were
coming in asbestos and concluded that this might mean that disinvestments were coming.
C. Organizational and Physical Location of Field Staff May Change.
1. Key Findings.
C.I There is a significant difference in the total number of staff devoted to
fieldwork. ESD has 12 persons devoted full-time to fieldwork. Seven are at Fort Meade, MD,
and five at Wheeling, WV. Virtually all of their effort is devoted to inspections of industrial
facilities. In spite of the existence of these units which specialize in fieldwork, most Regional
managers, including those in ESD, who direct programs that require fieldwork, tend to rely on
their own staff to do the fieldwork. Based on the interviews of managers, about 150 EPA staff
devote a total of 75 EPA FTE to fieldwork. They are assisted by 11 SEE employees. Of that
total, 10.75 EPA FTE are located in ESD in programs such as Wetlands and Estuaries.
C.2 Region Ill's ESD inspectors are full-time field staff. When they are
not in the field, they are preparing for inspections, writing reports of past fieldwork, or taking
14
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training courses to improve their expertise. By contrast, 12 of the 23 program inspectors
interviewed said that fieldwork occupied no more than 15% of their time; nine said 15% to 30%;
and only two said 30% to 45%. None felt that they spent more than half of their time in the field.
C.3 The ESP inspector corps has a unique position and role in the
Region. The BSD inspectors have been working together as a group for 15 years with no new
inspectors being hired. An issue raised by several interviewees is that four of the 12 are currently
eligible for retirement and the others will be eligible in the next five to ten years. Eight of the
twelve will be eligible for retirement by. 2005 and the other four will be eligible by 2010. A great
deal of expertise and institutional memory will be lost unless a strategy is developed to hire and
train new inspectors while the existing ones are available to train them. On the other hand, if the
retirements occur as predicted, the Region will have a unique opportunity to redefine fieldwork
roles.
C.4 The ESP inspectors are the only EPA field personnel in the Region
who routinely take samples during inspections. The issue of who will take samples if the BSD
inspectors retire was considered particularly important, because many enforcement cases rely on
samples being taken and analyzed by federal employees. Only a few program field staff reported
that they took samples during FY'99. Two programs reported that they use contractors to take
samples. Enforcement attorneys said that the Department of Justice wanted all samples used in
court to be taken and analyzed by federal employees.
C.5 If another EPA organization takes the responsibility for sampling, it
will also have to make arrangements to house the items used for sampling. Provisions will have
to be made for the storage of chemicals and large items of equipment, boats and gas cylinders.
There are also safety and security aspects to the storage question.
C.6 Most program managers reported that they were satisfied with the
quality, quantity, and timeliness of the fieldwork that they received from BSD. There was a
concern expressed by the CERCLA Removal program that the OASQA was not always able to
accept a request to analyze a sample or that it did not always return reports as soon as they were
needed. This is viewed as a resource issue by the lab director. When the lab is operating at
capacity, it must use the contract lab program to analyze samples. This adds about a week to the
turnaround time for a sample. Recent changes in the way EPA accounts for staff time and
charges FTE to accounts have reduced the lab's ability to accept samples from some programs.
There was an issue with RCRA Enforcement concerning the delivery of reports. This was
discussed in the planning section, above.
2. Analysis.
The most revealing findings to the study team are that ESD's inspectors are but a
small part of the total resources the Region devotes to fieldwork and that there are no significant
complaints about the quality, quantity and timeliness of the fieldwork done by ESD's inspectors.
15
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The projected turnover in ESD's inspector corps is also very significant. The actual
organizational and physical location may not be significant.
The analysis of ESD resources made by the study team showed that, in the 1990's,
ESD field resources were cut more sharply than other resources in the same Program Elements.
Since the Program Elements were shared with program divisions and funded compliance and
enforcement activity in general, it is impossible to determine whether ESD was made to bear an
unfairly large part of the burden.
The potential retirement of ESD's inspectors was a point that they raised
themselves. They feel that they have an expertise and understanding that will be Idst unless they
can help to train their replacements. The questions of whether the replacements work for ESD or
the program divisions, or whether they are located in the field offices or in Philadelphia are not
as important as the transfer of expertise.
All of those interviewed who expressed an opinion felt that the number of
process-oriented inspections would increase during the next five years. WPD and ESD have
discussed training ESD inspectors to do process inspections. ESD managers felt that the change
from traditional inspections to process-based inspections would be good for the program.
On the other hand, the general feeling from the program managers was that the
demand for traditional inspections would not decrease in the near future. This is a point in favor
of keeping a core staff of full-time inspectors who can specialize in traditional fieldwork and
follow changes in techniques, equipment, etc., regardless of where such a unit is located.
However, there are not enough resources for ESD to maintain the current level of traditional
inspections and shift inspectors to process-based inspections. Some accommodation will have to
be made.
Part of the specialist role currently assigned to ESD is that of taking samples in
the field as part of inspections. Most program staff interviewed do not take samples. Some take
samples on occasion, but rely on ESD for the most part. Two programs (Superfund and RCRA)
currently use contractors to take some of their samples. ORC managers mentioned that legal
issues were often raised when samples were taken and analyzed by non-EPA staff. Frequently,
such samples can not be admitted as evidence in federal court trials.
D. Communication and Feedback Are Reported to Be Poor.
1. Key Findings.
D.I Communications and feedback are considered poor bv field staff.
especially those in ESD. The ESD inspectors feel that programs should provide more detailed
information about the objectives of inspections when they are scheduled. This is especially true
16
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if samples need to be collected or special equipment is required. Once the inspectors are in the
field, it is too late to find out that a sample should have been taken or special equipment used.
D.2 There is a need for program managers and ORC to provide feedback
to ESP inspectors in a timely manner, so they feel they are a part of a team and so they know
what does and does not work in terms of the techniques they are using. ORC managers
expressed a concern that fieldwork (inspection reports and samples) was "stale" when cases were
prepared. BSD field staff felt that they never had an adequate sense of the priorities involved in
inspections. The only program issue concerning communication was that of the late delivery of
inspection reports from BSD which was discussed in the section on planning.
D.3 There is also a general feeling among program field staff that the
feedback that is provided is negative and counterproductive from the field staffs point of view.
Additionally, the wrong person may be given the feedback, so that changes are never made.
2. Analysis.
The critical role in the communications issue is that of the program staff who rely
on BSD for fieldwork. Both inspectors and attorneys complained that communications were
poor. Some of the issues, such as "stale" samples and no feedback on the utility of the
inspections, clearly need better communication between the program staff, who are in the middle,
and the attorneys and inspectors. In other cases, more direct interaction between attorneys and
inspectors may be needed.
The ORC issue of "stale" samples is complex. According to field staff in BSD
and the programs, it is very hard to duplicate the conditions under which a sample was taken.
Therefore, field staff prefer not to retake samples to support an enforcement action for fear that
the violation will not appears second time.
The question of programs providing complete information on scheduled
inspections was also discussed in the section on Planning, above. However, it is clear that the
BSD inspectors feel that they are kept in the dark about the purpose of inspections and the
equipment they will need in the field. BSD inspectors and managers stressed that they need to
schedule fieldwork well in advance and that a late request, or the failure to specify that a sample
will be needed, cannot be made up once the inspectors have gone into the field.
E. Support for Fieldwork Varies Widely.
1. Key Findings.
E.I There are resource issues concerning support for field personnel.
BSD inspectors raised no concerns involving equipment needs or operational funds, but field
staff in several programs noted that travel dollars were inadequate and that operational funds
17
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were limited in FY'99. If the BSD inspector functions were "reinvented" and transferred to other
organizations, there would also be a question of how to handle the equipment currently held by
the ESD inspectors.
E.2 Inspectors in several organizations said that they did not have
sufficient training to do their jobs well. The actual degree of the problem varied greatly. EPA
Order 3500.1, promulgated in 1988, sets training requirements for field personnel. Virtually all
staff doing fieldwork have taken the 40 Hour Safety Training course which is part of the 3500.1
requirement. Again, almost all inspectors have received the basic training in how to do an
inspection which is mandated by the Order. All ESD inspectors have received the basic
programmatic training for each type of inspection that they perform for program offices.
However, only the APD field staff among the program staff interviewed reported that they had
met the program training requirements of 3500.1. Some program staff had started the training,
but had learned their jobs through observation. In some programs, no formal training curricula
have been established. The absence of training curricula is a national issue; only ten of 17 EPA
programs have established formal 3500.1 protocols, although all were required to. A revision to
3500.1 is currently being prepared. It will tighten the requirement and set a mandatory
requirement for all programs.
E.3 The role of Regional managers in fieldwork training is not clearly
understood. Regional managers who supervise staff who do formal fieldwork under 3500.1 are
responsible for making sure that their staff has been trained under 3500.1. First-line supervisors
of persons doing fieldwork are also required to take the relevant training for their program. No
formal count of how many first-line supervisors have taken the training was done as part of the
study, but there was confusion and little awareness among the interviewees on these points. The
issue of training needs to be emphasized. In particular, all affected staff need to be made aware
of the relevant requirements that pertain to them.
E.4 The staff who reported that they had received the required training.
those in ESD and APD. had their own issues with training. Specifically, both said that advanced
programmatic training was lacking and ESD said that they had had trouble getting an adequate
explanation of new regulations. On several occasions, a Region III staff expert in RCRA who
sits on national regulation-writing work groups has been able to brief ESD inspectors on new
RCRA regulations that he has helped draft. However, this person does not sit on all work
groups.
2. Analysis.
The issue of providing adequate support for field staff in program offices should
be a significant factor in management's consideration of the future organization of fieldwork.
The ESD inspectors have the advantage of being in one unit. Equipment, travel and training
needs can be managed for the group as a whole and support the primary mission of the group.
18
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Program staff who do fieldwork as part of a larger job, do not have the advantage of having a
specialized organization providing for them.
If the Region decides to eliminate a centralized corps of inspectors, there will be
no group or person specializing in inspections. Based on the experiences of the program
inspectors, there would still be a need for a coordination function or focal point for fieldwork.
There would also be a need to consider how to handle the logistics and equipment associated
with inspections. The field staff in Wheeling and Fort Meade have equipment ranging from
cameras and sampling kits on up to boats and cylinders of compressed gases that have special
storage needs.
Many of the training problems appear to represent national issues that arose in the
early 1990's and that are being corrected by the revision to EPA Order 3500.1. A national
workgroup has been preparing the revision. Region III has a representative on the group.
The current draft of the revised Order proposes a requirement that each RA and
AA designate a staff member who would maintain a list of all field staff in their organization and
track the training status of each to make sure that only qualified staff go into the field.
V. Summary of Information Sources.
A. Introduction.
Section V. includes a summary of all data collected for the study. It begins with the
results of the interviews of the program managers who rely on fieldwork to fulfill their program
commitments. The subsections that follow summarize the interviews of ESD managers and ESD
inspectors; program field staff; staff from other Regions; and OECA managers in Headquarters.
The study team also reviewed ESD resource allocations, and ESD internal study and EPA
Order 3500.1. TRAINING AND DEVELOPMENT FOR COMPLIANCE INSPECTORS/
FIELD INVESTIGATORS. Summaries of those analyses are also included.
Throughout this report, a common list of programs is used. It was developed by the study
team in consultation with the Advisory Committee. The study team also reviewed the Program
Manager interviews and the Region's functional statements to make sure that the list was
comprehensive. The final list appears at the top of page 20.
19
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Programs with Potential Fieldwork Needs:
WCMD Lead:
RCRA Corrective Actions
RCRA Enforcement (Hazardous Waste)
UST/LUST
RCRA Municipal Waste
EPCRA Enforcement
FIFRA
Asbestos (TSCA, AHERA, NESHAPS)
TSCA (PCB, Lead)
APD Lead:
CAA Enforcement (Titles I, III, IV, V, and
VI)
Air Planning
Air Monitoring
Air Modeling
Radiation
WPD Lead:
NPDES Enforcement
SDWA Enforcement
Water Quality (Standards, Planning)
NPDES Permit Issuance
Non-Point Source (NFS) Pollution/CZARA
Total Maximum Daily Load (TMDL)
Ground Water Protection
Construction Grants and State Revolving
Fund (SRF)
ESD Lead:
Ocean Monitoring
Water Monitoring - Streams, Lakes, Rivers
Wetlands
NEPA Compliance
Estuaries
OECEJ Lead:
Multi-Media Enforcement
HSCD Lead:
Oil Spill
EPCRA
CERCLA (Removal)
CERCLA (Remedial)
CID Lead:
Criminal Enforcement
B. Program Manager Interviews.
All program managers who were identified by the Advisory Committee as needing
fieldwork were interviewed. The managers interviewed (40 in all) and the complete
questionnaire are listed in the Appendices. The analysis of the interview results is organized
according to the questions asked.
20
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1. Types of Fieldwork Needed.
Program managers were asked two questions; one, define the fieldwork needs of
each program and, two, identify the types of fieldwork needed at the present (i.e., FY'99). The
results are contained in Table V-l. The responses are organized according to the activity types
identified in the definition of fieldwork used for this study.
The table contains no entries for RCRA Municipal Waste, Air Modeling, Water
Quality (Standards & Planning), NFS Pollution/CZARA, Ground Water Protection, Construction
Grants SRF, and CERCLA (Remedial). For those programs, the program managers did not
identify any type of fieldwork activity during the interview. The types of fieldwork activity are
listed below along with the abbreviations used in the tables that follow:
1) Statutory Inspections (Statlnsp) 5) Site Cleanups (SiteClnp)
2) Compliance Inspections (Comlnsp) 6) Monitoring/Ambient Sampling (MonSmpl)
3) Case Development (CaseDev) 7) Environmental Assessments (EnvAsst)
4) Emergency Response (EmerRes) 8) State Oversight (StatOver)
Table V-l lists the types of fieldwork needed across the top of each column, and
the programs along the left hand side of each row. Using RCRA Corrective Action as an
example, the types of fieldwork activities needed are: Compliance Inspections, Case
Development, Site Cleanups, Monitoring/Ambient Sampling, Environmental Assessment, and
State Oversight.
In addition to identifying fieldwork needs, the program managers were asked to
identify the purpose of the fieldwork. The six choices for purpose were Monitoring, Quality
Assurance, State Oversight, Compliance with Permit, Case Development, and Site Assessment or
Cleanup. The results are contained in Table V-2. For each program, more than one fieldwork
need can be attributed to a particular purpose of fieldwork.
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Table V-l. Types of Fieldwork Needed.
PROGRAM
RCRA Corrective Action
RCRA Enforcement (Hazardous Waste)
UST/LUST
RCRA Municipal Waste
EPCRA Enforcement
FIFRA
Asbestos (TSCA, AHERA, NESHAPS)
TSCA (PCB, Lead)
CAA Enforcement (Titles I, III, IV, V & VI)
Air Planning
Air Monitoring
Air Modeling
Radiation
NPDES Enforcement
SDWA Enforcement
Water Quality (Standards & Planning)
NPDES Permit Issuance
Statlnsp
Comlnsp
CaseDev
EmerRes
SiteClnp
MonSmpI
EnvAsst
StatOver
Statlnsp = Statutory Inspections CaseDev
Comlnsp = Compliance Inspections EmerRes
= Case Development SiteClnp = Site Cleanup
= Emergency Response MonSmpI = Monitoring and Sampling
EnvAsst = Env. Assessment
StatOver = State Oversight
22
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Table V-l. Types of Fieldwork Needed, continued.
PROGRAM
Non-Point Source (NPS) Pollution/CZARA
Total Maximum Daily Load (TMDL)
Ground Water Protection
Construction Grants and SRF
Ocean Monitoring
Water Monitoring - Streams, Lakes, Rivers
Wetlands
NEPA Compliance
Estuaries
Multi-Media Enforcement
Oil Spill
EPCRA
CERCLA (Removal)
CERCLA (Remedial)
Criminal Enforcement (CID)
Statlnsp
Comlnsp
CaseDev
EmerRes
SiteClnp
MonSmpI
EnvAsst
StatOver
Statlnsp = Statutory Inspections CaseDev
Comlnsp = Compliance Inspections EmerRes
= Case Development SiteClnp = Site Cleanup
= Emergency Response MonSmpI = Monitoring and Sampling
EnvAsst = Env. Assessment
StatOver = State Oversight
23
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Table V-2. Purposes of Fieldwork.
PROGRAM
RCRA Corrective Action
RCRA Enforcement (Hazardous Waste)
UST/LUST
RCRA Municipal Waste
EPCRA Enforcement
FIFRA
Asbestos (TSCA, AHERA, NESHAPS)
TSCA (PCB, Lead)
CAA Enforcement (Titles 1, III, IV, V & VI)
Air Planning
Air Monitoring
Air Modeling
Radiation
NPDES Enforcement
SDWA Enforcement
Water Quality (Standards & Planning)
NPDES Permit Issuance
Non-Point Source (NPS) Pollution/CZARA
Monitoring
QA
State
Oversight
Compliance
Permit
Case
Development
Site Assmnt/
Cleanup
24
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Table V-2. Purposes of Fieldwork, continued.
PROGRAM
Total Maximum Daily Load (TMDL)
Ground Water Protection
Construction Grants and SRF
Ocean Monitoring
Water Monitoring - Streams, Lakes, Rivers
Wetlands
NEPA Compliance
Estuaries
Multi-Media Enforcement
Oil Spill
EPCRA
CERCLA (Removal)
CERCLA (Remedial)
Criminal Enforcement (CID)
Monitoring
QA
State
Oversight
Compliance
Permit
Case
Development
Site Assmnt/
Cleanup
25
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(This page intentionally left blank.)
26
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2. Resources Available for Fieldwork.
Program managers were asked to identify the resources they use (or rely on) for
fieldwork. The results are contained in Table V-3. The responses are organized according to the
eight categories that were presented during the interview. The RCRA Municipal Waste, NFS
Pollution/CZARA, Ground Water Protection, Construction Grants and SRF, and CERCLA
(Remedial) programs did not perform fieldwork. The eight choices are:
1) Own Staff
2) Other Branch/Office in your Division
3) BSD
4) Other Region III Divisions
5) National EPA Organizations (NEIC, etc.)
6) Other Federal Agency (programmatic or IAG)
7) Contract (HQ or Regional)
8) State and Local Agencies (not delegated)
Table V-3 lists the means used to accomplish fieldwork across the top of each
column and the programs along the left hand side of each row. Using RCRA Corrective Action
as an example, the resources used for accomplishing fieldwork are: Own Staff, Other
Branch/Office in your Division, Other Federal Agency (programmatic or IAG), Contract (HQ or
Regional), and State and Local Agencies (not delegated).
Table V-4 lists the resources programs use to meet their fieldwork needs. The
resources correspond to the providers cited in Table V-3. Own Staff has been subdivided into
EPA staff and SEEs. The National EPA Organizations and Contract (HQ or Regional) categories
have been subdivided to account for both contract dollars and FTE. Two categories (Other
Branch or Office in your Division and Other Division in Region III) were not included because
the respondents could not quantify the support they received from them. The figures in the ESD
column represent the managers' estimates of the resources they provided to ESD to support their
programs' fieldwork.
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Table V-3. Resources Used to Accomplish Fieldwork.
PROGRAM
RCRA Corrective Action
RCRA Enforcement (Hazardous Waste)
UST/LUST
RCRA Municipal Waste
EPCRA Enforcement
F1FRA
Asbestos (TSCA, AHERA, NESHAPS)
TSCA (PCB, Lead)
CAA Enforcement (Titles 1, III, IV, V & VI)
Air Planning
Air Monitoring
Air Modeling
Radiation
NPDES Enforcement
SDWA Enforcement
Water Quality (Standards & Planning)
NPDES Permit Issuance
Own
Staff
V
Other
Branch/
Office
in Div.
ESD
Other
Region
HI
Division
National
EPA
Orgs.
Other Federal
Agency
Program
IAG
Contract
HQ
-
Regional
State/
Local
28
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Table V-3. Resources Used to Accomplish Fieldwork, continued.
PROGRAM
Non-Point Source (NPS) Pollution/CZARA
Total Maximum Daily Load (TMDL)
Ground Water Protection
Construction Grants and SRF
Ocean Monitoring
Water Monitoring - Streams, Lakes, Rivers
Wetlands
NEPA Compliance
Estuaries
Multi-Media Enforcement
Oil Spill
EPCRA
CERCLA (Removal)
CERCLA (Remedial)
Criminal Enforcement (CID)
Own
Staff
Other
Branch/
Office
in Div.
ESD
Other
Region
III
Division
National
EPA
Orgs.
Other Federal
Agency
Program
IAG
Contract
HQ
Regional
State/
Local
29
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Table V-4. Specific Fieldwork Resources Reported by Program.
PROGRAM
RCRA Corrective Action
RCRA Enforcement (Hazardous Waste)
UST/LUST
RCRA Municipal Waste
EPCRA Enforcement
FIFRA
Asbestos (TSCA, AHERA, NESHAPS)
TSCA (PCB, Lead)
CAA Enforcement (Titles 1, III, IV, V & VI)
Air Planning
Air Monitoring
Air Modeling
Radiation
NPDES Enforcement
SDWA Enforcement
Water Quality (Standards & Planning)
NPDES Permit Issuance
Own Staff
EPA
(FTEJ
8.5
1.5
0.6
0.2
0.2
1.5
0.6
5.3
0.2
1.2
0.1
12.6
2.8
1.8
SEE
1.1
4.0
0.5
4.0
FTE
given
to ESD
(Insp)
4.5
0.6
1.0
6.0
0.3
0.5
National
EPA
(FTE;
Contract
(FTE)
National
EPA
($$)
Other
Fed IAG
($$)
433,863
20,000
Contract
HQ
($$)
130,000
15,000
Contract
Region
($$)
893,223
50,000
15,000
State &
Local
($$)
30
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Table V-4. Specific Fieldwork Resources Reported by Program, continued.
PROGRAM
Non-Point Source (NPS) Pollution/CZARA
Total Maximum Daily Load (TMDL)
Ground Water Protection
Construction Grants and SRF
Ocean Monitoring
Water Monitoring - Streams, Lakes, Rivers
Wetlands
NEPA Compliance
Estuaries
Multi-Media Enforcement
Oil Spill
EPCRA
CERCLA (Removal)
CERCLA (Remedial)
Criminal Enforcement (CID)
Totals
Own Staff
EPA
(FTE)
1.0
1-3
8.5
1.5
4.0
1.3
0.1
16.8
3.6
74.9
SEE
0.4
0.5
0.5
10.9
FTE
given
toESD
(Insp)
12.9
National
EPA
(FTE)
1.0
1.0
Contract
(FTE)
40.0
40.0
National
EPA
($$)
10,000
10,000
Other
Fed IAG
($$)
"
300,000
753,863
Contract
HQ
($$)
Contract
Region
($$)
100,000
5,200,000
6,258,223
State &
Local
($$)
4,500,000
4,500,000
31
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3. Safety Training.
Program managers were asked if personnel performing the fieldwork had
completed the required Occupational Health and Safety Training. The safety training
requirements are established under EPA Order 3500.1, TRAINING AND DEVELOPMENT
FOR COMPLIANCE INSPECTORS/FIELD INVESTIGATORS.
All program managers who supervised staff who did fieldwork said that their staff
had received the relevant training. Program managers who used fieldwork provided by other
offices in their divisions, or by ESD, where not always sure of the training status of the staff who
did the fieldwork for them.
Program managers stated a concern that the recent retirement of the person who
tracked the safety training status of field staff may result in some staff missing refresher training.
The safety officer in the Office of Policy and Management has assumed this function and is
taking steps to make sure that safety training is up to date for all field staff.
4. Projecting and Scheduling Fieldwork.
Program managers were asked how fieldwork is projected and scheduled.
Fieldwork is projected and scheduled any one or more of four primary ways: MOAs with
Headquarters, ESD workplans, on an as-needed basis, or with the states.
Programs that schedule MOAs with Headquarters do so on an annual basis. The
MOAs are negotiated between the Regional and Headquarters program managers. Regional
workplans are negotiated with ESD and are prepared on a semi-annual or annual basis. In past
years, ESD required that programs negotiate separate workplans with OEP for inspections and
OASQA for analysis of samples. Starting in FY'99, OEP is negotiating single ESD workplans
with the programs. This approach was welcomed by the program managers.
EPCRA and CERCLA (Removal) do not schedule inspections. These programs
contact ESD on an as-needed basis when they need to have inspections performed. There is no
advance planning other than their past record of inspections. Case Development and Emergency
Response fieldwork is almost always scheduled on an as-needed basis.
Finally, those programs that schedule the majority of fieldwork with the states do
so on a quarterly or annual basis. The process is usually done through meetings between the
Regional and State staff. FIFRA and Asbestos fall into this area.
32
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Figure V-l.
Figure V-l shows the breakdown of how fieldwork is scheduled.
Scheduling and Projecting Fieldwork
Programs with
Headquaters MOAs
No
68.0%
BSD Workplans
No
56.0%
1, Yes
11 ?"~44.0%
As- needed Basis
No
16.0% '
21 ..-:
-"'' Yes
" 84.0%
No
80.0%
States
Yes
20.0%
Eight programs utilize Headquarters MOAs:
1. EPCRA Enforcement
2. TSCA (PCB, Lead)
3. CAA Enforcement (Titles I, III, IV, V & VI)
4. Air Planning
5. Multi-media Enforcement
6. Oil Spill
7. EPCRA
8. CERCLA (Removal)
Eleven programs utilize Regional workplans with ESD:
1. RCRA Corrective Action
2. RCRA Enforcement (Hazardous Waste)
3. UST/LUST
4. TSCA (PCB, Lead)
5. NPDES Enforcement
6. SDWA Enforcement
7. TMDL
8. Ocean Monitoring
9. Water Monitoring - Streams, Lakes,
Rivers
10. Wetlands
11. Estuaries
33
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Twenty-one programs project and schedule fieldwork on an as needed basis:
1. RCRA Corrective Action 12. SDWA Enforcement
2. RCRA Enforcement (Hazardous Waste) 13. NPDES Permit Issuance
3. UST/LUST 14. Ocean Monitoring
4. EPCRA Enforcement 15. Water Monitoring - Streams, Lakes,
5. Asbestos; Rivers
6. TSCA (PCB, Lead) 16. NEPA Compliance
7. CAA Enforcement (Titles I, III, IV, V & VI) 17. Multi-media Enforcement
8. Air Planning 18. Oil Spill
9. Air Monitoring 19. EPCRA
10. Radiation 20. CERCLA (Removal)
11. NPDES Enforcement 21. Criminal Enforcement
Three programs use the states to accomplish some types of fieldwork (this category was for
programs not delegated to the states):
1. FIFRA
2. Asbestos
3. Air Monitoring
5. Quality. Quantity, and Timeliness of Fieldwork.
Program managers were asked if they were satisfied with the quality, quantity
and timeliness of the fieldwork they were receiving. Most program managers reported that they
were satisfied with fieldwork performed for them by ESD. All were satisfied with fieldwork
provided by their own staffs.
Four managers, representing four programs, expressed dissatisfaction with the
fieldwork that ESD was providing. The programs were RCRA Enforcement (Hazardous Waste),
UST/LUST, Criminal Enforcement and CERCLA Removal. Several ORG managers also had
problems with fieldwork, but they use fieldwork provided by other programs.
RCRA Enforcement and UST/LUST program managers were dissatisfied with the
quality, quantity and timeliness of the fieldwork they were receiving from ESD. Specifically,
inspection reports did not arrive from ESD in a timely manner. The managers cited an instance
in which 24 of 40 inspection reports were delivered in one day rather than ten per quarter. In
interviews with ESD, the inspectors and one OEP manager stated that the targeting lists for
RCRA Enforcement and UST/LUST did not arrive until the second or third quarter of the fiscal
year. The late arrival made it difficult to properly schedule inspections and provide inspection
reports hi a timely manner.
34
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A CID manager expressed dissatisfaction with the lack of analytic capacity
available to the program. OASQA stated this is because of the lack of non-Superfund FTE
resources given to the lab and the limited flexibility caused by charging to the same budget
Objective as the FTE allocation. Thus, OASQA must charge most analyses to Superfund. If
CID has a sample that does not involve Superfund, OASQA may not have FTE available to
analyze the sample.
The CERCLA Removal program's concern with timeliness of analytic support is
also related to OASQA. When the lab is at capacity, samples are analyzed through the contract
lab program. Use of the contract lab program delays the prompt delivery of reports. This is
because OASQA must perform data validation of the sample (e.g., to ensure analysis was done
according to the contract, etc.).
Several ORC managers also raised a timeliness issue. Fieldwork can go "stale"
when cases are prepared because there is always a delay between the date the inspection was
made and the date a case goes to court. In some cases, the delay can be several years long. The
ESD field staff said that they preferred not to do new sampling when a case was being
developed, because it was always possible that the new sampling would be done under different
conditions and undermine the case by confusing the issue. A related concern, also from ESD
field staff, was that programs are not always clear in asking for samples or in explaining what the
purpose of an inspection is.
6. Fieldwork Needs in the Next Three to Five Years.
Program managers were asked to predict if their fieldwork needs would change in
the next three to five years. Most programs saw a need for increased fieldwork in general or non-
specific terms. Specific changes were noted by. the TMDL, SDWA Enforcement, RCRA
Corrective Action, RCRA Enforcement, and Asbestos programs.
The TMDL program has been expanding for several years and that trend is
expected to continue because of consent decrees settling law suits. EPA and the states need to
conduct special ambient monitoring studies to support TMDL preparation. If the states are not
able to meet all the monitoring needs, EPA will have to provide the information. A major issue
in the lawsuits are claims that the 303(d) lists do not reflect current data. Program managers for
the Water Monitoring - Streams Lakes, and Rivers Program are currently hard-pressed to meet
the needs of the TMDL program in light of declining resources.
The Safe Drinking Water Program is preparing to issue eleven new regulations.
EPA will have to do significant fieldwork as these regulations are promulgated, implemented and
delegated to the states. Because the states cannot implement the regulations until they are
finalized, the SDWA Enforcement Branch will have to do all the fieldwork for each regulation
until the process is completed.
35
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The asbestos program is changing, but program managers are receiving mixed
signals. First, ORC has been told that future asbestos cases will be more complex and require
more fieldwork. Second, CID has been told to stop pursuing asbestos cases and instead
Headquarters has advised them to take on larger, more complex cases. Third, TSCA program
staff have been told to expect big changes in the asbestos program, but have interpreted this as a
warning that cutbacks are coming. Fourth, program managers stated that because of the large
amount of non-compliance in the AHERA program, resources should be increased or the
program should be eliminated. It is unclear what is going to happen in the next three to five
years. Program managers have heard about disinvestment of small programs like TSCA, PCB
and asbestos. Fifth, the Senior Environmental Employees (SEEs) now hired as inspectors for the
asbestos program are not permitted to enter the containment area at demolition sites. This is an
occupational safety requirement imposed by a grant condition. As a result, SEEs are not able to
testify to actual conditions observed.
Process-based inspections are expected to cause fieldwork increases in the RCRA
Enforcement and CAA Enforcement programs. RCRA Enforcement (Hazardous Waste)
program managers expect to move towards process based inspections which will look at the
entire process of the facility. These inspections are more resource-intensive than traditional
compliance inspections. CAA Enforcement (Titles I, III, IV, V, and VI) program managers
expect to do more detailed work in the future. They expect to do fewer cases, but the cases will
have greater impact. The CAA Enforcement staff will need knowledge in the manufacturing
process, emissions, more complicated rules, etc., to handle the work. They are projecting that
they will need to hire individuals with a science background to accomplish this technically
oriented work. In addition, one program manager cited concern of the retirement of the ESD
Inspectors.
One ORC manager expressed concern about the integrity of sample analysis.
Citing an instance with the City of Philadelphia, the manager stated that, when a contract lab
performs the sample analysis, there can be problems with the results as well as the chain-of-
custody. While not currently an issue, there is a potential for future concerns as the states and
local agencies begin to perform sample analysis.
Only one program, RCRA Corrective Action, expected decreases in their
fieldwork needs. This is because the states will be responsible for the permits.
36
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C. ESP Interviews.
1. Background.
The Study Team interviewed managers and staff from the Office of
Environmental Programs (OEP) (located in Philadelphia, Ft. Meade and Wheeling) and
managers from the Office of Analytical Services and Quality Assurance (OASQA) in Ft. Meade.
The interviews covered six topics. The topics are types of fieldwork; planning; inspections,
sampling and sample analysis; training; and the future of fieldwork.
2. Types of Fieldwork.
OEP managers were asked to identify the types of fieldwork for which they are
responsible. The managers stated that the ESD inspectors performed every type of fieldwork (as
defined in this study). When questioned specifically about case development, the OEP managers
indicated that the ESD inspectors perform case development only sporadically. For case
development, both civil and criminal actions, the ESD inspectors provided updated information
and would also testify in criminal cases.
There are twelve inspectors in OEP (five in Wheeling and seven in Ft. Meade).
Each inspector is trained in several programs. Table V-5 shows the number of inspectors trained
in each program. Occasionally, contractors might accompany the/ Ft. Meade staff into the field,
but this was at most five instances in FY '99. Also, the Region might use NEIC for specialized
inspections at federal facilities.
3. Planning.
To plan and schedule fieldwork for the year, ESD negotiates a workplan with
some programs. The programs, in turn, provide a list of facilities to be inspected. Although the
workplans exist, OEP managers stated that high priority work, such as emergencies and time-
sensitive inspections, can supersede the planned workload. In the past, programs would have to
negotiate separate workplans with OEP and OASQA, In FY'99, ESD negotiated a consolidated
workplan with each Division.
The inspectors did not feel the scheduling process was effective across all
programs. The inspectors felt they were inspecting the same RCRA and UST/LUST facilities
repeatedly. The inspectors, as well as one OEP manager, identified targeting lists provided by
the RCRA Enforcement, TSCA, EPCRA, and UST/LUST programs as problematic. The
inspectors stated that these lists did not arrive until the second or third quarter of the fiscal year.
The inspectors stated that the lists contained limited and sometimes inaccurate information. The
OEP managers and the inspectors felt that this made it difficult to schedule their work and to
provide inspection reports in a timely fashion. For example, the RCRA Enforcement program
37
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was late in submitting its targeting list, and then received twenty-four of its inspection reports in
one day.
One OEP manager noted two opportunities to improve fieldwork planning. First,
the OEP manager stated there was no Regional vision for inspections. That is to say, the Region
has not clearly defined whether or not inspections are conducted to find violations or maintain a
federal presence (to support this, several inspectors could not identify common objectives to
inspections). The nature of inspections, the manager stated, was dependent upon the objectives.
This vision needs to be defined before fieldwork can be properly prioritized and scheduled.
Second, the OEP manager identified one method to improve targeting schemes. The OEP
manager said State inspection reports could be used for targeting. Staff would review state
inspection reports and then follow-up with the problematic sites immediately.
4. Inspections. Sampling and Analysis of Samples.
The OEP managers and the ESD inspectors disagreed on the value of program
staff accompanying the inspectors. The OEP managers stated there was no additional value from
program staff accompaniment. The ESD inspectors, however, stated there were significant
differences. The inspectors state that if program staff accompany them on inspections, the ESD
inspectors receive less questions about the resulting inspection report. OECEJ staff, the ESD
inspectors noted, can direct them during the inspections. The ESD inspectors stated that when
staff accompanied them for the Drinking Water inspections, they provided beneficial knowledge.
The inspectors stated that the frequency of sampling was dependent upon the
program. For example, RCRA samples are collected only when there is a potential problem;
NPDES is a non-sampling inspection. The inspectors reported that they collect samples on
approximately 25% of their inspections. The samples are first sent to OASQA. If OASQA is
unable to handle the samples, the Client Services Team procures a contract lab each time.
Whether or not OASQA will analyze the sample is dependent upon the following factors.
OASQA may be unable to handle another sample due to workload constraints or the lab may not
have the technical capability to analyze the sample. If the samples are from the Wheeling
inspectors, they are usually sent to the University of West Virginia because it is closer than Ft.
Meade, Maryland. In Wheeling, there is also a biological group used for analytic support. The
biological staff consists of two EPA FTE and two SEEs. The ESD inspectors located in Ft.
Meade do not make use of the Wheeling Biological Support Group.
OASQA managers identified several reasons for delayed sample analysis.
Arranging for and employing a contract lab is more time-intensive than sample analysis done at
Ft. Meade. There may be internal difficulties such as instrument malfunctions. The quality of a
sample can also impede progress; a bad sample could cause the data system to malfunction. A
sample might not include the necessary information which OASQA must then obtain. If a
scheduled sample does not arrive on time, then its allocation will be given to another sample and
the sample analysis must be rescheduled. As the OASQA managers note, there is also a resource
38
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issue. Several programs have shown an interest in increased sampling as well, but the lab is
unable to accommodate them without additional FTE.
The OASQA managers identified difficulties with the Contract Lab program for
non-Superfund programs. There is specific protocol for the Superfund program and contracting
labs are familiar with it because it has been in place for some time. Using contract labs to
analyze samples from non-Superfund programs is a comparatively new practice; the labs are not
familiar with EPA procedures. Also, the same strict protocols are not in place for the non-
Superfund programs.
5. Communication.
The inspectors felt that additional feedback was needed from the EPCRA, NPDES
Enforcement, RCRA Enforcement programs. The ESD inspectors stated they would like
feedback on the quality of their reports and the status of the cases but did not feel they were
getting either. The ESD inspectors stated they would like to be told if their inspection reports
require improvements.
Both the OEP and OASQA managers identified some improvements in
communication, partially credited to the new consolidated workplan. As stated above, ESD now
negotiates one workplan per Division, incorporating both OASQA and OEP. The ESD
inspectors also noted improved communications because of it. Another communication
difficulty is advanced notice for sampling. One manager noted that the lab would prefer 90 days
advance notice before a sample arrives. To address this, the inspectors and the lab schedule
sampling on a quarterly basis. OASQA has also signed an MOU with OEP in which they detail
the necessary communication and coordination for samples.
6. Training.
Currently, all twelve ESD inspectors are trained in two or more programs. Table
V-5 displays the programmatic training each ESD inspector has received. The location of each
inspector is also provided.
39
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Table V-5. ESD Inspector Training
Inspector
Inspector #1
Inspector #2
Inspector #3
Inspector #4
Inspector #5
Inspector #6
Inspector #7
Inspector #8
Inspector #9
Inspector #10
Inspectoral!
Inspector #12
Location
Ft. Meade
Ft. Meade
Ft. Meade
Ft. Meade
Ft. Meade
Ft. Meade
Ft. Meade
Wheeling
Wheeling
Wheeling
Wheeling
Wheeling
Programs
RCRA, UST/LUST, Asbestos
RCRA, TSCA, EPCRA, NPDES, CWA
RCRA, EPCRA, NPDES
RCRA, UST/LUST, NPDES (Field Audit Inspections),
SDWA, Superfund
TSCA (PCBs), EPCRA, NPDES
UST/LUST, NPDES, Asbestos
RCRA, UST/LUST, TSCA, EPCRA, NPDES, SDWA,
CWA
RCRA, UST/LUST, NPDES
UST/LUST, TSCA (PCBs), Ambient Air Monitoring
EPCRA, NPDES
TSCA (PCBs), EPCRA, NPDES
NPDES, SDWA
The ESD inspectors and OEP managers raised an issue concerning training for
new regulations. When new regulations are promulgated, it was felt that the inspectors should be
given training on how the new regulations apply to the inspections. The inspectors felt that the
training was basic when it should also be advanced and continuing. The inspectors mentioned
that when training is provided on new regulations, it is incomplete because the training is
provided by a contractor lacking the necessary expertise. The inspectors would prefer being
trained by the EPA staff who wrote the regulation and met with the stakeholders. They feel that
these individuals could provide detailed and specialized answers to their questions.
A related issue raised by the ESD inspectors and OEP managers involves
synopses of new regulations. They stated that they were rarely given a clear synopsis of how to
interpret new regulations. As an example, one ESD inspector cited the PCB "Mega Rule"
promulgated several years ago. One RCRA staff member has written synopses for the ESD
inspectors. However, this is not a regular occurrence and done only when the RCRA staff
member participates on a regulatory development work group.
40
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7. Future of Fieldwork.
The OEP managers and some of the ESD inspectors cited the possible retirement
of BSD inspectors as a crucial issue. Eight of the twelve inspectors will be eligible to retire by
2005. Significant amounts of expertise and institutional knowledge will be lost at that point.
The OEP managers and ESD inspectors felt that not enough was currently being done to address
this problem. To prevent this loss of expertise and knowledge, the OEP managers and ESD
inspectors would like to see new staff hired. The new staff members could be placed in a
mentoring program with senior staff members.
A new development was the changing nature of inspections. Two managers cited
a different method of inspections which provided for more collaboration between the programs,
ESD and ORC. This new method would mean involving the inspectors in case development.
The managers noted that, to implement such a new approach, training would have to be provided.
While the nature of inspections will change, OEP managers stated that there will always be a
need for sampling. Currently, ESD inspectors are the only EPA staff who take samples. Should
program field staff begin to take more samples, storage of the necessary equipment will become
an issue. This equipment could not be stored in the Regional office.
D. Program Field Staff Interviews.
1. Background.
The Study Team interviewed staff in program offices who do fieldwork, primarily
inspections, in addition to other duties. There were 23 staff members interviewed. The staff
were identified by Advisory Committee members as being representative of the staff
who do fieldwork. Field staff from the following programs were interviewed:
SOW AEnforcement NPDES Enforcement
CAA Enforcement EPCRA Enforcement
TSCA (PCB, Lead) Water Monitoring
Wetlands Enforcement RCRA Enforcement
Emergency Response/Oil Spill UST/LUST
CERCLA (Removal) FIFRA
Asbestos (NESHAPS) Multi-media Enforcement
2. Types of Fieldwork.
The program field staff were asked to identify the types of fieldwork they
perform. As with the first interviews with program managers, responses to the types of
fieldwork and the purpose of the fieldwork mirrored each other. The program field staff
predominantly performed compliance inspections and case development. Case development was
the most cited purpose for fieldwork.
41
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Figure V-2. Time Spent Performing Fieldwork
0-15% 16-30% 31 -45%
Percent of Time spent Performing Fieldwork
Program staff perform other duties in addition to the fieldwork mentioned above.
Among the duties identified were the following: reviewing inspection reports (SDWA
Enforcement, UST/LUST); administrative duties (all programs); state oversight for delegated
programs (NPDES Enforcement; RCRA Enforcement); coordinating enforcement (EPCRA
Enforcement); FOIAs (EPCRA Enforcement; FIFRA); grants management (NPDES
Enforcement); compliance assistance (RCRA Enforcement); writing inspection reports
(CERCLA Removal); managing lab contract (Asbestos); and managing'data tracking (FIFRA).
The program staff also identified the percentage of time spent performing
fieldwork. Figure V-2., below, lists the program field staff according to the percentage of time
spent performing fieldwork (0-15% of time spent performing fieldwork; 15-30%; 30-45%, etc.).
As stated, 23 program field staff members were interviewed. The Y-axis in Figure V-2. denotes
the number of inspectors who fell into each category of time spent performing fieldwork. Again,
these answers are not representative of the program, but only of the individuals interviewed.
The program staff were asked how they schedule fieldwork. The staff members
get their assignments and schedules directly from their supervisors; they are usually not involved
in negotiating MOAs with Headquarters.
Program field staff stated they were satisfied with how the fieldwork was
scheduled, but there were exceptions. TSCA staff cited that Headquarters targeting lists do not
arrive until very late in the year (April or May). This makes it difficult to effectively schedule
fieldwork. The Confidential Business Information (CBI) provided by the sources serves as the
42
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basis for the targeting lists. This information, however, is sent only to Headquarters. Therefore,
Headquarters must provide the targeting lists.
For most programs, the field staff reported, BSD takes the samples. There were
four exceptions to this. Program field staff from the RCRA Enforcement (Hazardous Waste) and
CERCLA Removal programs stated they use contractors to collect samples. SDWA
Enforcement staff members have collected samples infrequently but still continue to use ESD.
Program field staff for the Asbestos program collect samples.
As the ESD inspectors noted, program field staff rarely accompany ESD
inspectors. Program staff accompanied ESD inspectors for multi-media inspections (SDWA
Enforcement, TSCA (PCBs), EPCRA Enforcement, Wetlands Enforcement, UST/LUST, Multi-
Media Enforcement); to take samples (NPDES Enforcement, EPCRA Enforcement, RCRA
Enforcement, Multi-Media Enforcement); or for large enforcement cases (TSCA and Asbestos).
The ESD inspectors located in Ft. Meade were also used as part of a lake monitoring effort
outside of their normal duties. EPCRA enforcement staff identified a difference when they are
present on an inspection. EPCRA enforcement staff stated that they know when inspections will
be used as evidence or require more work. Resource issues were a concern for several program
staff members. TSCA, UST/LUST, FIFRA and Multi-media Enforcement all cited a lack of
funds for travel as impeding their ability to perform fieldwork.
3. Training.
Program field staff raised concerns about protocols for technical training. The
following program staff expressed concern over a lack of specific training for inspections (as
opposed to on-the-job training): EPCRA Enforcement; TSCA; UST/LUST; RCRA
Enforcement; FIFRA, and Asbestos. Of these programs, however, EPA Order 3500.1 mandates
training protocols for TSCA, UST/LUST, RCRA Enforcement, FIFRA and Asbestos. The CAA
enforcement staff were the one group of program inspectors interviewed who were familiar with
EPA Order 3500.1 and who had completed the basic requirements of the Order.
The CAA Enforcement, Wetlands Enforcement and Multi-media Enforcement
programs cited a lack of on-going technical training. Specifically, Headquarters formerly
provided training for field staff, updating them on new areas. Much of this material has now
been placed on the IntraNet for self-training purposes. One CAA Enforcement program field
staff member cited training for Maximum Available Control Technology (MACT) as an
example. The program staff for all three programs also expressed concerns over a lack of travel
money to attend training not available on the IntraNet and some staff felt supervisors did not
really make training a priority. In addition, the program staff stated their ability to attend
training was restricted by workload.
43
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4. Communication with ORC.
Program field staff for several programs cited communication with ORC as an
issue. SDWA Enforcement (UIC), NPDES Enforcement, Oil Spill, CERCLA Removal and
Asbestos (NESHAPS) stated that they received no feedback from ORC. FIFRA programs
reported that they received positive feedback from ORC. RCRA Enforcement, UST/LUST and
Multi-media Enforcement cited that the feedback was mostly negative. Multi-media
Enforcement also stated that when they work with ORC before an inspection, the results are
much more positive. The program field staff felt that ORC wants more samples than the staff
can provide. However, field staff for the CAA Enforcement, EPCRA Enforcement, Wetlands
and stated they received positive feedback from ORC.
E. Environmental Services Division Resource Analysis.
An analysis was conducted of ESD FTE allocations for FY'89 through FY'99. ESD
allocations were presented by program element through FY'98. The allocation system was
changed in FY'99 to align the resource allocation with the Agency's strategic plan in accordance
with GPRA. The data for the total ESD allocations for FY'89 through FY'98 are contained in
Table V-6. The first four program elements listed in the table represent the ESD inspectors
located in the Ft. Meade and Wheeling offices. These FTE are solely utilized to support the
specific program fieldwork requirements. All four inspector program elements declined
significantly during the study period. ESD's allocation in Water Quality Enforcement declined
39%; Stationary Source Enforcement, 83%; Toxics Substance Enforcement, 81%; and Hazardous
Waste Enforcement OECA, 37%.
The remaining program elements represent all other non-inspector ESD FTE. The
following changes took place in non-inspector ESD FTE allocation from FY'89 to FY'98. Water
Quality Monitoring was redesignated Watershed Protection in FY'92. Dredge & Fill was
redesignated Wetlands Protection in FY'91. The UIC Program became part of Groundwater
Protection in FY'92. PWSS Program Implementation was redesignated Drinking Water
Implementation in FY'92. Environmental Education, Wastewater Management, Pollution
Prevention, Wetlands Protection Enforcement, Federal Facilities Enforcement, and HS - Federal
Facilities are program elements where ESD received FTE allocations in the last four years. ESD
lost FTE allocations from Permit Issuance, Emergency Planning and Chesapeake Bay.
44
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Table V-6. ESD FTE Allocation FY'89 Through FY'98.
PROGRAM ELEMENT
Inspector
FTE
Non
Inspector
FTE
Water Quality Enforcement
Stationary Source Enforcement
Toxic Substance Enforcement
Hazardous Waste Enforcement
Inspector Sub-Total:
Air Quality Monitoring
Planning, Evaluation & Analysis
Ocean Disposal Permits
Env Review &Coordination
Coastal Env Management
Water Quality Monitoring to
Watershed Protection
Dredge & Fill to
Wetlands Protection
UIC Program to
Groundwater Protection
PWSS Prgm Implementation to
Drinking Water Implementation
Environmental Education
Wastewater Management
Pollution Prevention
Wetlands Protection Enforce
Federal Facility Enforcement
HS-Federal Facilities
HS-Technical Enforcement
HS-Spill & Site Response
Permit Issuance
Emergency Planning
Chesapeake Bay
Non Inspector Sub-Total:
ESD Total:
1989
11.20
5.20
3.20
7.10
26.70
7.90
3.50
1.60
9.80
5.00
12.40
8.60
0.70
0.70
8.40
14.50
0.20
0.05
0.50
73.85
100.55
1990
9.90
4.10
3.00
7.10
24.10
7.90
3.90
1.70
10.80
5.20
11.30
9.70
0.30
0.80
11.60
16.00
0.20
0.50
79.90
104.00
1991
10.50
4.70
3.20
7.30
25.70
8.30
4.30
1.60
9.60
7.20
11.60
14.40
0.30
1.00
1.80
. 1.10
10.50
15.90
0.20
0.60
88.40
114.10
1992
10.50
5.00
3.20
7.60
26.30
8.80
4.30
1.60
9.60
9.50
11.60
13.90
0.30
1.10
2.50
2.10
10.70
15.70
0.20
0.70
92.60
118.90
1993
10.20
3.10
3.10
7.40
23.80
8.40
4.00
2.30
8.90
7.70
10.60
13.60
0.30
1.20
2.40
2.00
9.80
14.60
0.20
0.40
86.40
110.20
1994
7.60
3.10
3.10
7.30
21.10
8.10
4.10
2.70
8.40
5.30
11.30
13.50
0.30
1.20
2.40
'2.10
10.40
15.30
0.20
86.30
106.40
1995
7.30
2.00
1.50
6.90
17.70
9.00
4.00
2.80
7.70
3.60
10.40
13.60
0.40
1.30
2.30
2.00
9.80
21.90
0.30
89.10
106.80
1996
6.30
1.30
0.90
4.70
13.20
8.50
4.20
2.60
7.00
3.00
10.70
11.20
0.30
1.00
0.20
0.30
2.60
3.00
0.60
7.10
23.40
86.70
98.90
1997
7.20
1.00
0.50
5.00
13.70!
8.40
2.30
2.70
6.40
3.10
10.20
10.90
0.30
1.10
0.20
2.00
2.70
2.80
0.90
7.60
23.00
84.60
98.30
1998
6.80
0.90
0.60
4.50
12.80
8.00
2.60
2.80
7.50
2.60
12.90
11.00
1.10
1.30
1.00
0.20
2.00
2.70
2.80
0.70
7.40
23.90
90.50
103.30
45
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ESD resources also fluctuated between FY'97 and FY'99 because of Regional
reorganizations. Part of the increase from FY'97 to FY'98 reflects the addition of environmental
education, XL and CSI functions to ESD as part of the Internal Assessment reorganization. The
decrease from FY'98 to FY'99 is mainly due to the transfer of functions and FTE to the Office of
Reinvention. Figure V-3 shows the change in total ESD FTE for FY'89 through FY'99.
Figure V-3.
ESD FTE Allocation (Total)
125-,
120-
19(89 19911993 1995 1997 1999
1990 1992 1994 1996 1998
Fiscal Year
Figure V-4 shows only the ESD inspector program elements for FY'89 through
FY'98. All of the ESD FTE for these program elements declined. Water Quality Enforcement
dropped from 11.20 to 6.80 FTE, Stationary Source Enforcement dropped from 5.20 to 0.90
FTE, Toxics Substance Enforcement dropped from 3.20 to 0.60 FTE, and Hazardous Waste
Enforcement dropped from 7.10 to 4.50 FTE over this ten year period.
Figure V-4. FTE Allocation for ESD Inspectors
Water Quality Enforcement
Stationary Source Enforcement
-*- Toxics Substance Enforcement
« Hazardous Waste Enforcement
1989 1990 1991 1992 1993 1994 1995 1996 1997 1998
46
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The decline in ESD inspector resources in these specific four program elements
was not mirrored by the other divisions that receive FTE allocations in these same program
elements. Table V-7 has been prepared to show that ESD took a larger cut than all the other
applicable organizations combined for FY'90 through FY'98. ESD's allocation in the four
inspector program elements declined by 11.3 FTE, while the decline for all other applicable
divisions was 6.1 FTE. ESD's share was 65% of the total loss.
A portion of the loss for ESD reflects the division's role as the organization with
the largest concentration of inspectors. Another reason for the decline is the shift in some
programs from ESD inspectors to program field staff.
Table V-7. ESD Inspector Resources FY'90 Through FY'98
FTE Resource
ESD Inspector
All Other Divisions
Region III Total
Overall Program Element Change from FY'90 to FY'98
Water
Quality
Enforcement
-3.1
-1.2
-4.3
Stationary
Source
Enforcement
-3.2
5.5
2.3
Toxics
Substance
Enforcement
-2.4
-1.9
-4.3
Hazardous
Waste
Enforcement
-2.6
-8.5
-11.1
Total for All
Four Program
Elements
-11.3
-6.1
-17.4
EPA's resource allocation system changed in FY'99 to implement the new budget system
which was developed to implement the agency-wide strategic plan. Program elements were
combined into larger, more general groupings under the Goal, Objective, SubObjective structure
of the new system.
Table V-8 has been prepared to demonstrate how the resources moved from FY'98 to
FY'99. The table includes all ESD resources. Inspector resources, marked with an asterisk, are
cross-walked to Goal 9, Objectives 9.1 and 9.2. Although total ESD resources dropped during
this period, inspector resources stayed about the same. The problem is that the broader
groupings of resources makes it harder to make separate allocations to the functions that have
been joined. The table is for information purposes, providing a general FTE crosswalk between
the FY'98 Program Element Title and the FY'99 Program Results Code Titles in ESD.
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Table V-8. Crosswalk of ESD FTE Allocation - FY'98 to FY'99.
1998 Program Element Title
Air Quality Monitoring
Groundwater Protection
Drinking Water Implementation
Pollution Prevention
Ocean Disposal Permits
Watershed Protection
Wetlands Protection
Coastal Env Management
Wastewater Management
HS-Federal Facilities
HS-Technical Enforcement
HS-Spill & Site Response
Environmental Education
Planning, Evaluation & Analysis
Water Quality Enforcement*
Stationary Source Enforcement*
[Toxic Substance Enforcement*
Hazardous Waste Enforcement*
Wetlands Protection Enforcement
Federal Facility Enforcement
Environmental Review & Coordination
Totals
FTE Crosswalk
8.00
1.10
1.30
2.00
2.80
12.90
11.00
2.60
0.20
0.70
7.40
23.90
1.00
2.60
6.80
0.90
0.60
4.50
2.70
2.80
7.50
103.3
5.40
1.20
0.30
1.20
0.00
27.40
0.00
30.60
0.30
2.10
0.70
13.50
12.60
95.30
1999 Program Results Code Titles
NAAQSOzone/PM(l.l)
NAAQS CO/SO2/NO2/Lead (1.3)
Air Toxics (1.2
Safe Drinking Water (2.1)
Public's Ability to Red Exposure (7.2)
Conserve Nations Water (2.2)
Reduce Loadings &Air Depos. (2.3
Human Health Risks (5.1)
Prevent Releases (5.2
Educ., Outreach, Data Avail (7.1
Sector Based Env. Mgt.-Op (8.7
Reduce Non-Compliance (9.1
Auditing, Self-Policing Policies (9.2
F. Other EPA Regions.
1. Background.
Representatives from each of the other nine EPA regional offices were
interviewed as part of the study. The objectives for interviewing representatives from the other
Regional Offices were to determine how fieldwork was organized; if managers were satisfied the
allocation provided the best results; and if there was a formal mechanism to plan and schedule
fieldwork. A total of 14 regional managers were interviewed. Each region had at least one
representative, in some instances, a second person was contacted based on the recommendation
of the initial contact.
48
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2. Organization.
Seven Regions have field staff located either in a centralized unit or in the
programs. Region I stated that field staff are located in an Environmental Services Division
while field staff for Regions IV, V, VIII, IX and X are located in the programs. Region VI has a
separate Enforcement Division.
Two Regions had field staff in both a centralized unit and in the programs.
Region II has both an Environmental Services Division and an Enforcement.Division. Region .
VII has field staff in both an Environmental Services Division and in the programs.
Satisfaction with the organization of field staff varied from Region to Region. No
one type of organizational structure proved unanimously satisfactory.
G. Headquarters Input.
1. Interviews with OECA Managers.
Two managers in the Office of Enforcement and Compliance Assurance (OECA)
were interviewed. The objectives for contacting Headquarters were to determine, if there were
any national problems concerning fieldwork, what the Agency requirements are for inspectors,
and if these requirements would change in the immediate future, and also to get an overall
perspective of fieldwork in the Agency.
The two managers stated that the Agency has not used the latest technology
available to it. Specifically, EPA is not using the Internet, databases, or new and improved
sampling techniques currently available. These resources, one manager-noted, should be
available to the field inspectors.
The two managers also stated that the Agency's field inspector program is not
evolving and one manager noted the State programs have evolved faster than EPA. The two
managers reported that, within the next three-to-five years, the Agency will lose its institutional
knowledge as inspectors retire. Both said Region III is particularly vulnerable. The managers
recognized a need for additional training and the lack of communication between inspectors and
the program staff. They identified the immediate need for the Agency to better define and
restructure the inspector program or risk losing the program entirely. It was also mentioned that
there might be new directions inspections will take in the future; both managers stated that
Senior Management needed to invest more resources to explore these areas.
The managers stated that all field staff have to meet the requirements of EPA
Order 3500.1. There is basic health and safety training required of all field staff, but the program
specific training varies from program to program. Neither manager anticipated the training to
49
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change, although they did mention that the current Order is being revised and the new Order
should be out shortly.
2. National Training Requirements for Fieldwork.
In 1988, EPA established training requirements for all personnel who do
fieldwork in EPA Order 3500.1, TRAINING AND DEVELOPMENT FOR COMPLIANCE
INSPECTORS/FIELD INVESTIGATORS. The Order established training requirements for
compliance inspectors, field investigators, contractors, and first-line supervisors of inspectors
and investigators. The study team was made aware of the Order during the Headquarters
interviews.
There were three types of training identified in the Order: Occupational Health
and Safety Training; Basic Inspector Training; and Program-Specific Training. This last area,
Program-Specific Training, was further divided into Program-Specific Minimum Curriculum;
Program-Specific Specialized Curriculum; and multi-media or multi-program requirements.
The Order requires all EPA programs with fieldwork components to establish
Program-Specific Training curricula. A report was published as a supplement to the Order which
listed the programs then in existence which fell under the Order and outlines their curricula.
They were Air-Stationary Sources; Air-Mobile Sources; Comprehensive Environmental
Response, Compensation and Liability Act (CERCLA); National Pollutant Discharge
Elimination System (NPDES); Pesticides/Toxic Substances; Public Water Supply Supervision;
Resource Conservation and Recovery Act (RCRA); Underground Injection Control (UIC); and
Wetlands Protection.
The Order requires all EPA field personnel and their first-line supervisors to
complete the health training, the basic inspector training and the program-specific minimum
curriculum. EPA personnel included persons hired under grant programs such as the SEE
Program. It requires that a person doing inspections under more than one program complete the
minimum curriculum for each. It recommended that field personnel complete the specialized
curriculum. It requires refresher training at least every three years.
Since EPA Order 3500.1 was released, new programs have come into existence.
Seven new programs fall under the purview of EPA Order 3500.1 and need to be included. The
programs are Asbestos (NESHAPS, AHERA), EPCRA, Food Quality Protection Act, Lead-
based paint, Oil Pollution Act, Stratospheric Ozone, and UST. As a result, the Order is being
rewritten, with a new guidance document, to make the requirements clearer and more self-
executing. A copy of the draft Order, which is being prepared for Agency-wide review, was
provided to the team. It incorporates all the requirements of the original Order and adds
language to clarify some sections and address new concepts such as team leaders.
50
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From a Regional perspective, one of the most important additions is the
requirement that each Regional Administrator designate an official who will be responsible for
implementing the Order in the Region by maintaining a list of persons covered by the Order and
making sure that they have completed the relevant training. Region III currently does this for
safety training but not for the other types of training covered by the Order.
H Comparison with the ESP Internal Study.
1. Background.
In July, 1999 BSD completed an internal study of fieldwork activities performed
by the ESD inspectors and sample analysis performed by OASQA. No formal assessment of
client satisfaction with ESD services had been undertaken for several years, and the study set out
to survey the status of ESD service. What follows is a comparison of that internal study with this
study conducted by SPMB.
2. Purpose and Scope.
The purpose of the internal study was to determine client satisfaction with the
services provided by the ESD inspectors and OASQA and to also identify solutions. While not
contrasting with the internal study, the fieldwork study does differ in purpose. The purpose of
the fieldwork study was to determine the fieldwork needs, Regionally, both now and in the next
three to five years and to assess the overall organization of Regional fieldwork personnel. The
internal study examined the present service and possible solutions; future issues were not
examined. Thus, the fieldwork study was both short and long-term in its objectives where the
internal study was immediate.
Also, while the ESD inspectors and the lab are significant aspects of Regional
fieldwork, they are by no means the entirety of it. The fieldwork study, concerned with the
Regional needs, examined topics beyond the needs of ESD clients. For the purposes of the
. internal study, the clients were identified as only the enforcement and compliance programs in
the WPD, WCMD, OECEJ, ORC, and CID. The personnel included program managers and
program staff. The internal study also included interviews with OECA staff from Headquarters.
The fieldwork study included all Regional offices as well as OECA staff from Headquarters and
staff from other Regions.
3. Methodology.
The methodologies for both studies were similar, relying on interviews as the
primary source of data. The studies' methodologies differed in several ways. The fieldwork
study's interviewees consisted of, but was not limited to, the internal study interviewees. The
fieldwork study also contains research on Executive Order 3500.1 and a resource analysis of
51
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BSD. The internal study first consulted with inspectors before conducting interviews. The
fieldwork study did not. These differences support the scope and purpose of each study.
4. Findings.
Despite differing purposes and scopes, the studies arrived at some similar
findings. Both studies identified a need for ESD inspectors to better document (the internal
study specifically noted additional photographs) the inspections. The fieldwork study and the
ESD study noted a need for improved turnaround time for inspection reports; however, the
fieldwork study noted that the ESD inspectors' ability to deliver timely reports was hampered by
the delayed arrival of the targeting lists from the programs. Both studies also noted limited
interaction between ESD and the programs and ORC. The two studies found that the ESD
inspectors were unclear about the purposes of inspections, ESD managers and inspectors
preferred a single workplan, and the ESD inspectors desired additional training for new
regulations and emerging programs. The retirement eligibility of the ESD inspectors was a
significant issue in both findings.
While there were no contradictions, there were differences in findings between the
two studies. These differences can be attributed to the differing scopes and purposes of the
studies. By focusing specifically on the inspectors and the lab, the ESD study delved into issues
the fieldwork study did not. The internal study raised sampling as a significant issue. This
included the ESD inspectors being unsure when sampling was necessary, a perceived insufficient
lab capacity for unanticipated sampling, and no agreement between programs and ORC as to
when samples were necessary. In the fieldwork study, sampling was one issue among many.
The internal study examined the consistency of services between the Wheeling
and Ft. Meade offices. The internal study reported clients felt that while there were benefits in
having two field offices (e.g., closer to inspection sites, savings in travel costs and time,
knowledge of the geographic area, etc.), the field offices differed in work scheduling, procuring
lab services, and variations in inspection procedures. The fieldwork study did not investigate
differences between the two field offices.
The fieldwork study, with its Regional focus, went beyond the fieldwork
performed by ESD. It noted that the physical location of field staff within the region is split
between the programs and ESD. The internal study did not note this. The fieldwork study also
found the program managers cited a shift in targeting facilities. The fieldwork study examined
programmatic training requirements as defined by EPA Order 3500.1. Moreover, the fieldwork
study examined'the future fieldwork needs but the internal study did not. Finally, the fieldwork
study noted that most programs were satisfied with the fieldwork they were receiving.
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Fieldwork Study - List of Appendices
Appendix A. Project Outline
Appendix B. Study Advisory Committee
Appendix C. Interview Questions
Appendix D. Interviewees
Appendix E. Study Team Members
Appendix F. EPA Order 3500.1
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Appendix A
Project Outline
Region TTT Ficldwork Study
GOAL for the REGION
Define the program requirements under GPRA for "inspections" and insure the
availability of competent and responsive "inspectors" to meet GPRA goals, Regional
priorities and environmental emergencies.
OUTCOMES for REGION HI
Create and maintain a core of competent, ready, trained staff for field activities.
Determine appropriate organizational locations and levels of inspector resources.
A
Meet present and future GPRA requirements
PRODUCTS of the STUDY
Develop a protocol for field work in Region in that allows all organizations to have their
field work needs met without confusion over who should do the work or delay in getting
it done.
Define and establish the conditions that will allow the first Outcome (create and maintain
a core of competent, ready, trained staff for field activities) to be achieved.
Develop a recommendation for the location and level of inspector resources in each
organization.
OBJECTIVES of the STUDY
Inventory current field work, including criminal enforcement, ambient monitoring,
compliance inspections, enforcement case development, emergency response, and any
other regular field activity.
Review current GPRA requirements, HQ MOAs, Region III RAPs and other Initiatives,
etc., to define field work requirements.
Define the core resource needs and organizational locations for each type of field work
and develop a plan to meet resource needs.
METHODOLOGY
Review the Agency Strategic Plan and Annual Activity Plan to inventory field work as
identified in those documents.
A - 1
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Survey regional managers through a brief questionnaire, with E-Mail, telephone follow-
up, to see if the information derived from the Agency's plans is complete. Develop an
inventory of needs not in the planning architecture.
Interview managers and key staff in organizations with field work needs and
responsibilities to determine if Region IE can actually meet the demand for field work.
Do a resource analysis of FTE, HQ and Regional contract dollars, and State and local
grant dollars devoted to field work.
Review past studies to establish benchmarks and trace historic trends in field work
demand, staffing and organizational location.
Define and evaluate the following criteria which have been suggested as being important
for field work.
- Cost effectiveness
- "Hit rate"/Federal Presence
- Health and Safety
- QA/COC
- Timeliness
- Audits (Self/outside)
- Integrity/behavior
- Inspector/case developer
- [How to] Measure success
- Customer expectations
PROJECT TEAM
Deputy Project, Bob Mitkus lead; Elaine Wright, co-lead.
- Support from other deputies as needed and negotiated by Bob.
Project Staffing from Strategic Planning and Management Branch
Division Contacts
- Carol Amend, ESD
A - 2
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- Others to be appointed by deputies through Bob Mitkiis
- Include OED as much as possible
TIMELINE
. Complete Project Outline by May 17
- Brief Tom Voltaggio May 20
- Inform other Senior Managers through an announcement at a Monday morning staff meeting,
probably May 24. Inform all employees through a LAN message from Tom Voltaggio
- Form and prepare Project Team from May 17 through June 10
- Project Team develops detailed methodology and holds meeting with divisional representatives
from May 25 through June 17
- Data Collection, June 20 through July 30
- Initial draft preparation and review, August 2 to 27
- Follow-up, additional data collection, rewriting, August 30 to September 23
- Prepare final draft, September 27 to October 15
- Final draft to typing, October 18
- Final concurrence, October 25
Final Report November 1,1999
- Present at Monday morning meeting November 7 or 14
- Develop an implementation plan as a follow-up to the Monday meeting
A - 3
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Appendix B
Study Advisory Committee
Divisional Representatives:
Glenn Hanson
Air Protection Division
Carol Amend
Environmental Services Division
Karen Melvin
Hazardous Site Cleanup Division
Elizabeth Barnes
Office of Enforcement, Compliance and Environmental Justice
Cecil Rodrigues
Office of Regional Counsel
Jeffrey Pike
Waste and Chemicals Management Division
Francis Mulhern
Water Protection Division
B-l
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Questionnaire
for
Program Managers
-------
Appendix C
Fieldwork Questionnaire
Person Interviewed: ; Date:
Interview Team: Interviewer: ;
Note-Taker:
Opening Statement:
The Strategic Planning and Management Branch is undertaking a study of fieldwork, at the
request of senior management, to better define the Region's needs and to make sure that we can
meet them. You have been identified as the manager of a program that uses field work. We
would like to ask you some questions about your fieldwork needs and the ways they are met.
Definition of Fieldwork:
Here is a copy of the definition of fieldwork that we are using. We will try to keep the
discussion focused on fieldwork in this sense.
1. How do you define the fieldwork needs of your program?
2. What types of fieldwork do you need at the present (i.e., FY 2000)?
a. Statutory Inspections
b. Compliance Inspections
c. Case Development
d. Emergency Response
e. Site Cleanups
f. Monitoring and Ambient Sampling
g. Environmental Assessments
h. Oversight of State Programs
C - 1
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3. Who does the fieldwork for you? (Repeat for each type of fieldwork needed.)
a. Own staff
b. Other branch/office in your division
c. ESD
d. Other Region III division
e. National EPA organization (NEIC, etc.)
f. Other federal agency
- as part of its programmatic functions
- under IAG with EPA
g. Contract
- Work Assignment on HQ contract
- Contract funded by Regional budget
h. State and local agencies (not delegated programs)
4. Do the people doing the fieldwork for you have the appropriate safety training?
5. What is the purpose of the fieldwork?
a. Monitoring
b. Quality Assurance
c. State Oversight
d. Compliance with Permit
e. Case Development
f. Site Assessment or Cleanup
C - 2
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6. How do you project and schedule fieldwork? (Repeat for each type of fieldwork needed.)
7. Are you satisfied with the quality, quantity and timeliness of the fieldwork you are receiving?
8. What is your estimate of the fieldwork needs of your program in the next three to five years?
C - 3
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Definition of "Field Work:"
"Field work" consists of activities performed out of the office for any type of fact-finding
purpose, whether they include sample collection, other environmental data collection (e.g.,
ambient and special purpose monitoring), observations relative to facility operation and waste
handling practices, identifying regulatory violations, overseeing site cleanup, or evidence
gathering; etc. Field work in this sense is generally carried out for four reasons: 1) to ensure that
the Federal laws are complied with and to properly document instances where this is not the case;
2) to provide necessary oversight of the State's field-related policies, procedures and capabilities;
3) for cleanup of hazardous waste sites; and 4) to maintain a "presence" for the regulated
community and to alert it that EPA is carrying out its regulatory responsibilities. Also included
in "field work" is the oversight of that portion of any contract which is let to perform field work.
Field work includes all of the following EPA activities:
- Statutory Inspections (e.g., RCRA, TSCA/FIFRA, UST);
- Compliance Inspections (all programs);
- Case Development (criminal and civil enforcement programs);
- Emergency Response (oil spills\EPCRA);
- Site Cleanup (CERCLA, RCRA);
- Ambient and Special Purpose Monitoring and Sampling (air and water programs);
- Environmental Assessments (NEPA); and
- Oversight of State Programs (all delegated programs).
All activities conducted in the field are not considered field work for purposes of this
definition. In general, any field visit for the purpose of enabling a program person to better
perform his/her job is not field work. For example, site visits for permit writers to gain
knowledge needed to write a good permit is not considered field work. Visits so that a program
person can become more familiar with a site in relation to an enforcement case or review of an
environmental assessment are also not field work. Some file reviews, such as those made to
target inspections or for case development, are field work. Others are not.
C - 4
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Questionnaire
for
ESD Program Managers
-------
FIELDWORK QUESTIONNAIRE FOR ESP STAFF
Person Interviewed: Date:
Interview Team: Interviewer:
Note-Taker:
Opening Statement:
The Strategic Planning and Management Branch is undertaking a study of field work, at the
request of senior management, to better define the Region's needs and to make sure that we can
meet them. We have'-interviewed about 45 managers in programs that use fieldwork. Many of
them are customers of yours. Now we would like to ask you some questions about how you and
your staff meet the fieldwork needs of your customers.
Definition of Fieldwork:
Here is a copy of the definition of fieldwork that we are using. We would like to focus our
discussion today on the types of fieldwork that your organization engages in that are included in
this definition.
1. Which types of fieldwork are you responsible for?
2. How do you schedule the fieldwork you do for the programs in the Region each year? Are
there negotiated agreements? e.g., MOAs? How do you handle emergencies and other
time-sensitive inspections?
3. Please identify the resources you devote to fieldwork (e.g., number of inspectors, and the
number of programs each is trained to do).
A. Do you use contractor support?
- Work Assignment on Headquarters contract
- Contract funded by Regional Budget
d
B. Is the workload supported by the requesting office, or do you have to make trade-offs?
C - 5
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4. Where are the samples taken during inspections analyzed?
5. How do you communicate with the analytical staff at the lab (Office of Analytical Services
and Quality Assurance)?
6. Do you use the biological group at Wheeling for analytical support?
7. Is there training that you feel is needed to allow the inspectors to do their jobs more
effectively?
8. Is there anything you feel would help to bring about more efficient and effective inspections
and reports?
9. How often do program staff accompany the inspectors? Are there significant differences in
service, quality, etc., when program staff are present?
10. Do the inspectors do case development work? Do the programs provide set protocols for
case development?
11. Do you feel that you have enough guidance and sampling/analytic support to prepare
complete cases for ORC?
12. What kind of feedback do you receive from the program offices about the results ofyour
work?
13. (For Gary & Leo) If you could prioritize and schedule fieldwork, would there be any
difference from what is happening now?
14. What do you think the future needs for fieldwork will be?
A. (For Gary & Leo) Do you foresee any training/equipment needs to prepare for
evolving areas of concern?
C - 6
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Questionnaire
for
ESD OASQA
-------
FIELDWORK QUESTIONNAIRE FOR OASOA
Person Interviewed: ' ; Date:
Interview Team: Interviewer:
Note-Taker:
Opening Statement:
The Strategic Planning and Management Branch is undertaking a study of fieldwork, at the
request of senior management, to better define the Region's needs and to make sure that we can
meet them. We have.interviewed about 45 managers in programs that use fieldwork. We have
also interviewed the ESD staff how schedule and supervise fieldwork. Many of those
interviewed in both categories are customers of yours. Now we would like to ask you some
questions about how you and your staff meet the analytic needs of your customers.
Definition of Fieldwork:
Here is a copy of the definition of fieldwork that we are using. Our discussion today will focus
on the services you provide to the programs.
1. How do you project and schedule the analytical work you do for the Region each year? Are
there negotiated agreements? e.g., MOAs. Is there a written process for scheduling fieldwork?
2. How do you communicate with the ESD field teams in Fort Meade, Philadelphia, and
Wheeling and their Office Director in Philadelphia concerning the analysis of fieldwork
samples?
3. Can you identify the circumstances or issues, either internal or external, which might cause
delays in completing your analyses?
4. Are there any problems with the contract lab program? Is there a difference between your
experience with Superfund and non-Superfund operations in the contract lab program?
C - 7
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5. Are you getting good quality samples?
A. Are there differences in quality depending on the source of the samples; i.e., BSD
inspectors, program inspectors, etc?
B. Are their QA project plans for dealing with samples?
6. What is your estimate of analytic needs in support of field work for the next 3-5 years?
7. Do you foresee any training/equipment needs to prepare for evolving areas of concern?
C - 8
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Questionnaire
for
ESD Inspectors
-------
FIELDWORK QUESTIONNAIRE FOR ESP INSPECTORS
Person Interviewed: Date:
Interview Team: Interviewer:
Note Taker:
Opening Statement:
The Strategic Planning and Management Branch is undertaking a study of fieldwork, at the
request of senior management, to better define the Region's needs and to make sure that we can
meet them. We have interviewed about 45 managers in programs that use fieldwork. We have
also interviewed the ESD staff how schedule and supervise fieldwork. Many of those
interviewed in both categories are customers of yours. Now we would like to ask you some
questions about how you and your staff meet the analytic needs of your customers.
Definition of Fieldwork:
Here is a copy of the definition of fieldwork that we are using. Our discussion today will focus
on the services you provide to the programs.
1) For which programs are you trained to conduct inspections?
2) Do you think the process for scheduling inspections across each program is effective in
helping you plan your work? Should it be changed in any manner?
3) Do you think there is a general sense the Region is consistent across all programs in the
objectives for inspections? (E.g., regulatory presence vs. finding violations)
4) Do you feel the training you have available is sufficient and timely to help you do your job?
5) In the course of your work how often are you asked to collect samples?
6) What kind of feedback do you receive from the program offices about the results of your
work?
7) Do program staff ever accompany you on inspections? Are there significant differences when
program staff are present?
C - 9
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Questionnaire
for
Program Inspectors
-------
Fieldwork Personnel Questions
1) Which types of fieldwork do you perform?
A. For which program?
B. Are you trained in additional programs?
2) What other duties do you have besides performing fieldwork? How much of your time is
spent performing them as opposed to fieldwork?
3) What is the purpose of the fieldwork?
a. Monitoring
b. Quality Assurance
c. State Oversight
d. Compliance with Permit
e. Case Development
f. Site Assessment or Cleanup
4) How do you schedule the fieldwork?
A. Do you think the process for scheduling fieldwork is effective in helping you plan
your work?
B. Should it be changed in any manner?
5) Do you feel the training you have available is sufficient and timely to help you do your job?
6) In the course of your work how often are you asked to collect samples? Where to send the
samples to be analyzed? Do you have any problems with quality assurance or timeliness?
7) What kind of feedback do you receive from ORC about the results of your work?
8) Do you or other staff in your program ever accompany the ESD inspectors?
A. Which circumstances would cause you to accompany the inspectors?
B. Are there significant differences when you or other program staff are present?
C - 10
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Questionnaire
for
Other EPA Regions
-------
Name
Position Title
Region
Date
Introduction - Region 3 is doing a study of field work to better define the Region's future needs
and to make sure that we will be able to meet them. To expand our study we felt that it was
necessary to see how fieldwork is addressed in other Regions. With that in mind, I would like to
ask you several questions.
Questions for other Regions
1. Within your region, where are your field work resources located?
2. Is your region satisfied with the organizational location of field work resources?
3. Is there a formal mechanism used to plan and schedule field work?
C-ll
-------
Questionnaire
for
Headquarters
-------
Name
Position Title
Region
Date
Introduction - It was recommended by Stan Laskowski in Region 3 to talk to you about field
work. Region 3 is doing a study of field work to better define the Region's future needs and to
make sure that we will be able to meet them. Stan felt that you could give a national perspective
of field work needs, etc. With that in mind. I would like to ask you several questions.
Questions for other Headquarters
1. What is your current position in headquarters?
2. What is your overall perspective of field work in the Agency?
3. Have you noticed any national problems concerning field work?
4. What are your requirements for field work inspectors at the National level0
5. Do you anticipate that these requirements will change in the next 3-5 years?
C - 12
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Appendix D
INTERVIEWEES*
Program Managers
Air Protection Division
Bernard Turlinski, Associate Division Director, Office of Enforcement and Permits Review
Christopher Pilla, Chief, Air Enforcement Branch
Marcia Spink, Associate Division Director, Office of Air Programs
David Arnold, Chief, Ozone and Mobile Sources Branch
Makeba Morris, Chief, Technical Assessment Branch
Robert Kramer, Chief, Energy, Radiation and Indoor Environment Branch
Chesapeake Bay Program
Richard Batiuk, Associate Director, Science Cluster
Environmental Services Division
Charles App, Acting Associate Division Director, Office of Ecological Assessment and
Management
Richard Pepino, Associate Division Director, Office of Environmental Programs
Thomas Slenkamp, Deputy Associate Division Director, Office of Environmental Programs
Gary V. Bryant, Deputy Associate Division Director, Office of Environmental Programs
Leo Clark, Team Leader, Ft. Meade Inspectors, Office of Environmental Programs
Patricia Krantz, Associate Division Director, Office of Analytical Services and Quality
Assurance
Cynthia Metzger, Deputy Associate Division Director, Office of Analytical Services and
Quality Assurance
Hazardous Site Cleanup Division
Dennis Carney, Chief, Removal Branch
David Wright, Chief, Preparedness and Program Support Section
Charlie Kleeman, Chief, Removal Response Section
Karen Melvin, Chief, Removal Enforcement and Oil Section
*positions and titles as of July 1999
D-l
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Office of Enforcement, Compliance and Environmental Justice
Samantha Fairchild, Director
Office of Environmental Data
Alvin Morris, Director
Office of Reinvention
Barbara D'Angelo, Director
Waste and Chemicals Management Division
Wayne Naylor, Chief, Technical Support Branch
John Humphries, Chief, State Programs Branch
Paul Gotthold, Chief, PA Operations Branch
Robert Greaves, Chief, General Operations Branch
James Webb, Associate Division Director for Enforcement
Harry Daw, Chief, RCRA Compliance and Enforcement Branch
Donald Lott, Chief, Pesticides/Asbestos Programs and Enforcement Branch
Aquanetta Dickens, Chief, Toxics Programs and Enforcement Branch
Water Protection Division
Joseph Piotrowski, Associate Division Director, Office of Watersheds
Evelyn MacKnight, Chief, PA/DE Branch
Robert Koroncai, Chief, VA/WV Branch
Patricia Gleason, Chief, MD/DC Branch
Victoria Binetti, Associate Division Director, Office of Municipal Assistance
Richard Rogers, Chief, Drinking Water Branch
David McGuigan, Associate Division Director, Office of Compliance and Enforcement
Kevin Magerr, Acting Chief, NPDES Branch
Karen Johnson, Chief, Safe Drinking Water Branch
D-2
-------
Office of Regional Counsel
Martin Harrell, Senior Regional Criminal Enforcement Counsel
Joseph Donovan, Chief, Site Remediation Branch II
Robert Smolski, Chief, Air Branch
Stephen Field, Chief, Water and General Law Branch
Mary Coe, Chief, Waste and Chemical Law Branch
Neil Wise, Associate Regional Counsel, Office of Site Remediation
Criminal Investigations Division
James Thompson, Deputy Division Director
ESP Inspectors
Gerald Crutchley, Office of Environmental Programs
Marilyn Gower, Office of Environmental Programs
George Houghton, Office of Environmental Programs
Gerald Donovan, Office of Environmental Programs
Charles Hufnagle, Office of Environmental Programs
Program Inspectors
Water Protection Division
Roger Reinhart, Safe Drinking Water Branch
Robert Sanchez, NPDES Branch
Anthony Meadows, NPDES Branch
Robert Lange, Safe Drinking Water Branch
Air Protection Division
Richard Killian, Air Enforcement Branch
Angela McFadden, Air Enforcement Branch
James Hagedorn, Air Enforcement Branch
D-3
-------
Waste and Chemicals Management Division
Charlene Creamer, Toxic Programs and Enforcement Branch
Craig Yussen, Toxic Programs and Enforcment Branch
Kenneth Cox, RCRA Compliance and Enforcement Branch
Michael Cramer, RCRA Compliance and Enforcement Branch
Andrew Clibanoff, RCRA Compliance and Enforcement Branch
Carmine DiSanzo, Pesticides/Asbestos Programs and Enforcement Branch
Richard Ponak, Pesticides/Asbestos Programs and Enforcement Branch
Todd Lutte, Pesticides/Asbestos Programs and Enforcement Branch
Environmental Services Division
Charles Kanetsky, Office of Ecological Assessment and Management
Jeffrey Lapp, Office of Ecological Assessment and Management
Hazardous Sites Cleanup Division
Michael Welsh, Removal Enforcement and Oil Section
Neeraj Sharma, Removal Enforcement and Oil Section
Glen Lapsley, Removal Enforcement and Oil Section
Office of Enforcement, Compliance and Environmental Justice
Paul Dressel, Environmental Engineer
Zelma Maldonado, Environmental Engineer
Garth Connor, Environmental Scientist
Other EPA Regions
Region 1:
Elizabeth Deabay, Unit Leader, Environmental Services Division
Carol Wood, Acting Deputy, Eco System Protection
D-4
-------
Region 2:
Randy Braun for Dore La Posta, Acting Chief, Monitoring and Assessment Branch
Laura Livingston, Enforcement Coordinator, Division of Enforcement and Compliance
Assistance
Patricia Sheridan, Acting Deputy Director, Division of Environmental Science and
Assessment
Region 4:
William Cosgrove, Lead Regional Coordinator, Science and Eco System Support Division
Sherri Fields, Chief, Accountability Management Branch
Region 5:
George Schupp, Central Regional Laboratory Coordinator
Region 6:
Charles Gazda, Chief, Response and Prevention Branch
Michael Machaud, Chief, Surveillance Section in the Enforcement Division
Region 7:
Alan Wehmeyer, Regional Comptroller and former Director of ESD
Region 8:
Thomas Willingham, Chief of Field Inspections
Region 9:
Joanne Semones, Senior Associate of Enforcement in the Office of the DRA
D-5
-------
Region 10:
Philip Wong, Manager, Office of Environmental Assessment Investigation and
Engineering Unit
Headquarters
Office of Enforcement and Compliance Assurance
David Lyons, Chief, Energy and Transportation Branch
Kenneth Gigliello, Associate Director, Manufacturing, Energy and Transportation
Division
D-6
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Appendix E
Study Team Members
Project Leads:
Robert Mitkus, Deputy Director
Office of Communications and Government Relations
Elaine Wright, Deputy Director
Air Protection Division
Branch Chief:
Mary A. Samo, Chief
Strategic Planning and Management Branch
Project Team:
Henry P. Brubaker
Program Analyst, Co-Team Leader
Jeffrey Boylan
Program Analyst, Co-Team Leader
Barbara L. Latsios
Program Analyst
Cindy Sobusiak
Program Analyst
Jada R. Goodwin
Management Analyst
Kevin Parker
Management Analyst
Michele Junker
Acting Management Assistant
Alicia Martinez
Secretary, Office Automation
Elizabeth Kamihira
Senior Environmental Employee
E-l
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Appendix F
6 EPA
Classification No.: 3500.1
Approval Data: Jre 29, 1968
TRAINING AND DEVELOPMENT FOR COMPLIANCE INSPECTORS/FIELD INVESTIGATORS
1. PURPOSE. ThisJ'Order establishes a consistent Agency-wide training and develop-
ment program for employees leading environmental compliance inspections/field
investigations.
2. APPLICABILITY. This Order applies to all Environmental Protection Agency (EPA)
personnel who lead or oversee the conduct of compliance inspections/field
investigations on a full- or part-time basis under any of EPA's statutes.
This Order is advisory to State and local agencies.
3. POLICY. It is the policy of the Environmental Protection Agency to ensure
that those who lead environmental compliance inspections/field investigations are
properly trained to perform these functions in a legally and technically sound
manner.
4. REFERENCES.
a. EPA 1440. Occupational Health and Safety Manual: Chapter 7, Occupational
Health and Safety Training.
b. EPA Order 1440.2, Health and Safety Requirements for Employees Engaged in
Field Activities.
c. EPA Order 1440.3, Respiratory Protection.
d. Agency-wide Program to Train/ Develop and Recognize Compliance Inspectors/
Field Investigators: A Program Description, June, 1988.
5. DEFINITIONS.
a. Compliance Inspection/Field Investigation Function. The function
includes leading, or overseeing State/local, contractor or other personnel
conducting, any of the following activities for the purpose of establishing the
A Form 1315-11* (9-86)
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EPA ORDER
6/29/88
compliance status of facilities or sites with applicable laws, standards, regulations
and permits and/or of supporting appropriate enforcement action (administrative,
civil judicial or criminal), including:
(1) planning and carrying out inspections of pollution abatement equipment,
relevant facility operations and maintenance practices, self-monitoring practices
and records, and laboratory equipment;
(2) gathering and developing evidence, including but not limited to emission
monitoring measurements, other analytical field procedures such as sampling and the
associated quality assurance procedures, and in-depth engineering evaluations; and
(3) maintaining field logs, recording field observations photographically,
analyzing sampling and emissions data, and preparing reports of observations along
with any supporting documentation.
Any EPA employee performing these activities regardless of job title or
program shall be considered a compliance inspector/field investigator for the
purposes of this Order. The terms compliance inspector/field investigator will be
used throughout this Order. This function does not include field activities or
investigations for purposes such as research and development, which are unrelated
to compliance monitoring or enforcement.
Not all individuals performing work as On-Scene Coordinators (OSCs) and
Remedial Project Managers (RPMs) under the CERCLA program are covered by the
definition of the compliance inspection/field investigation function. Additional
program guidance will .be developed to assist Regions in distinguishing these
functions from other programmatic responsibilities.
b. New Compliance Inspector/Field Investigators. Including:
(1) Individuals newly employed by EPA subsequent to the issuance date
of this Order regardless of previous training in and experience leading environ-
mental compliance inspections/field investigations, or
(2) Individuals rehired by EPA or transferred within EPA, subsequent
to the issuance date of this Order, with no previous training in and experience
leading environmental compliance inspections/field investigations.
c. Experienced Compliance Inspectors/Field Investigators. Including:
Individuals who were employed by EPA on the issuance date of this policy,
and/or who have previous training in and experience leading environmental
compliance inspections/field investigations in any one of EPA's compliance and
enforcement programs.
d. First-line Supervisors of Inspectors. A first-line supervisor is the
immediate supervisor of the day-to-day work of an individual who leads or
oversees compliance inspections/field investigations. The first-line supervisor,
who is responsible for the official performance appraisal, may be "new" or
"experienced" as defined above in items 5(b) or 5(c).
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EPA ORDER 3500.1
6/2S/88
e. Contract Inspectors and Others* This category includes contract
personnel and employees of a grantee organization under the.Senior Environmental
Employment Program, performing compliance inspections/field investigations under
EPA's statutes.
f. Leading an Inspection. Leading an inspection means independently
conducting a compliance inspection/field investigation or directing an
inspection/investigation with others as support staff.
g. Curriculum. Curriculum refers to defined content presented in a
sequence of supervised self-study, formal on-the-job and/or classroom training:
(1) Supervised Self-Study. Self-study means any knowledge gained
through independent, personal study, and overseen by a first-line supervisor or
an experienced inspector/investigator.
(2) On-the-Job Training. On-the-job training (OJT) means structured
training that relates principles or theories to work-related skills which are
demonstrated and applied in the field environment during an actual compliance
inspection/field investigation.
(3) Classroom/classes. This refers broadly to any form of instruction,
flexible in format and size, to include seminars, workshops, lecture-type or
video-assisted classes, or question-and-answer sessions following prior
independent self-study, that fosters group interaction with an instructor or an
experienced inspector.
h. Completing Required Training, completion of requirec1 training means
completing self-study, OJT and participation in classes cove'r'uj the content
described in applicable training curricula.
6. TRAINING PROGRAM. EPA's training program consists 01 three parts Occupa-
tional Health and safety Curriculum, Basic curriculum, and Program-Specific
Curricula as follows.
a. Occupational Health and Safety Curriculum. EPA Order 1440.2 establishes
basic, intermediate, advanced and refresher requirements for occupational
health and safety training for a.U EPA employees before engaging in any field
activities. In addition, EPA compliance inspectors/field investigators must
meet requirements, where these apply, of EPA Order 1440.3 for Respiratory
Protection. A summary of the curriculum is found in Appendix B of Reference
4(d) above. Contractor personnel must meet training requirements of applicable
regulations of the Occupational Safety and Health Administration (OSHA).
b. Basic Inspector Curriculum. This Curriculum establishes required
training to provide a comprehensive overview of knowledge and skills needed for
compliance inspections/field investigations under any EPA statute. It consists
of a course, that integrates legal, technical and administrative subjects, with
communication skills. It also includes the Occupational Health and Safety
Curriculum cited in 6(a) above. The Basic Curriculum is summarized in Appendix C
of Reference 4(d) above. Related Supplemental Training is recommended to-further
develop some of these skills, as summarized in Appendix F of Reference 4(d) above.
-3-
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EPA ORDER 3500.1
6/29/88
c. Program-Specific Curricula. The Program-Specific Minimum Curriculum
for each major environmental program establishes required training in legal,
programmatic and technical subjects. Any EPA compliance inspector conducting
inspections in more than one program is required to have completed the relevant
Program-Specific Minimum Curricula in each such program. Program-Specific
Specialized Training is recommended to further develop inspection skills.
Summaries of these curricula are available in Appendix D, of Reference 4(d) above.
A summary of multi-media (multi-program)training recommendations is available in
Appendix E of Reference 4(d) above.
d. Refresher Training.
(1) Occupational Health and Safety; EPA Orders 1440.2 and 1440.3
require refresher training annually.
(2) Basic and Program-Specific Minimum Curricula: Refresher training in
both the Basic Curriculum and Program-Specific Minimum Curricula is strongly
recommended, but at the discretion of the first-line supervisor. At a minimum,
refresher training should occur every three years, or more frequently, depending
on the needs of the individual, and changing emphases or needs in the compliance
and enforcement program.
7. REQUIREMENTS AND EXCEPTIONS.
a. Before Any Field Activities. All compliance inspectors and first-line
supervisors of inspectors are required to complete applicable occupational
health and safety training before any field activities as defined in EPA Orders
1440.2 and 1440.3.
b. Before Leading Inspections/Investigations. All compliance inspectors/
field investigators must complete the Basic Curriculum and the Program-Specific
Minimum Curriculum in the assigned program area(s) before leading an inspection.
Experienced inspectors may be.excepted from the Basic Curriculum, but new
inspectors may not. There .may be limited exceptions to program-specific require-
ments for new and experienced inspectors.
c. Within One Year When Supervising. The requirements to complete the
Basic and Program-Specific Minimum Curricula apply to first-line supervisors
of compliance inspectors. First-line supervisors shall meet these requirements
within one year of appointment to the supervisory position, if they have not
already done so. If the first-line supervisor directs inspectors/investigators
in two or more programs, the supervisor may need additional time to complete all
of the applicable Program-Specific Minimum Curricula, and should do so as soon
as practicable. Experienced first-line supervisors may be excepted from the
Basic Curriculum, but new ones may not. There may be limited exceptions to
program-specific requirements for new and experienced first-line supervisors.
d. Procedures for Exceptions.
(1) Health and Safety Training. Any exceptions to the occupational
health and safety training requirements must be in accordance with Paragraph
9(d), EPA Order 1440.2, or the provisions of 1440.3.
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EPA ORDER 3500.1
6/29/88
(2) Basic and Program-Specific Minimum Curricula. In the Regions,
exceptions must be aoproved by the Regional Administrator. Delegation below
this level nay be maae to the Deputy Regional Administrator or a cross-regional
panel of managers established for this purpose, but excluding the immediate
first- or second-line supervisor of the individual for whom the exception is being
requested. For Program Offices with inspectors based in Headquarters, the
Assistant Administrator shall approve exceptions for those inspectors. Delegation
below this level may be made to the Deputy Assistant Administrator, or Office
Director, or in the case of OECM, to the Director of the National Enforcement
Investigations Center (NEIC). The first-line supervisor shall prepare a written
request based upon guides for evaluating the previous knowledge, experience
and/or training of the inspector, and shall submit this to the approving official,
according to procedures adopted in the Region or Headquarters, whichever apply.
A copy of the approved 'written request shall be placed in the employee's official
personnel file along with other training records.
8. EFFECTIVE DATE.
a. Occupational Health and Safety Training. The requirements of EPA
Orders 1440.2 and 1440.3 are in effect and will remain in effect.
b. Basic and Program-Specific Minimum Curricula. This Order is effective
on the date of issuance; however, requirements are phased in as follows:
(1) New Inspectors. Beginning October 1, 1989, new inspectors shall
not lead inspections unless they have completed the Basic Curriculum, and have
completed, or have been formally excepted, from the Program-Specific Minimum
Curricula.
(2) Experienced Inspectors. Beginning October 1, 1991, experienced
inspectors shall not lead inspections unless they have completed or have been
formally excepted from the Basic and Program-Specific Minimum Curricula.
(3) First-line Supervisors. Beginning October 1, 1989, all first-line
supervisors shall meet the requirements of this Order or have been formally
excepted within one year of appointment to the supervisory position, or as
soon as practicable, for those with two or more programs.
(4) Contract Inspectors and Others. Training requirements for EPA
contract inspectors shall be appropriately phased into future contracts or
solicitations involving compliance inspection work. These requirements shall
be incorporated into future assistance agreements awarded under the Senior
Environmental Employment Program involving compliance inspections.
9. RESPONSIBILITIES. This section lists the primary responsibilities for
implementing this Order. Appendix G of Reference 4(d) above contains a more
detailed list of responsibilities.
a. Assistant Administrator for Enforcement and Compliance Monitoring (OECM).
The Assistant Administrator for Enforcement and Compliance Monitoring is
responsible for:
(1) Updating this Order, and overseeing and evaluating implementation.
of the overall program requirements every 3 years;
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EPA ORDER 3500.1'
6/2?/88
(2) Developing, updating and disseminating student manuals and
instructor's guides for the Basic Curriculum to the Regions, coordinating the
selection of and maintaining a list of instructors from the Regions and Head-
quarters; and
(3) Organizing a board of Senior Agency Managers from Headquarters
and Regions, and inspectors/investigators to advise him/her in carrying out
the responsibilities listed above.
b. Assistant Administrator for Administration and Resources Management.
The Assistant Administrator for Administration and Resources Management is
responsible for:
(1) Updating and providing sufficient materials for occupational
health and safety training, or approving non-EPA courses to meet the requirements
of EPA Orders 1440.2 and 1440.3, and reviewing program-specific health and safety
training.
(2) Training and evaluating EPA personnel designated as instructors
for delivering the Inspector Health and Safety Curriculum; and
(3) Coordinating and disseminating a timely schedule of classes
of the Health and Safety, Basic, and Program-Specific Curricula, in consultation
with OECM, Program Offices and the Regions.
c. Assistant Administrators. The Assistant Administrators are responsible
for:
(1) Implementing the requirements of this Order and Agency program
[Reference 4(d)] within their areas of jurisdiction, including periodically
evaluating implementation;
.(2) Developing, updating, and disseminating materials and schedules
for classes under the Program-Specific Curricula, in consultation with Regions
and states, and providing a plan by October 30, 1988, for implementing the Basic
Curriculum for inspectors based in Headquarters;
(3) Establishing guides for first-line supervisors of inspectors
to evaluate the training and development needs of compliance inspectors/field
investigators and approving requests for exceptions;
(4) Determining who among those inspectors/investigators based in
Headquarters are subject to this Order, and reviewing and approving exceptions
to the training requirements requested for these personnel.
(5) Ensuring in future contracts and assistance agreements awarded
under the Senior Environmental Employment Program involving compliance inspections!
that training is required by means of statements of work or other appropriate
vehicles; and
(6) Establishing standing work groups including Regions, and states where
appropriate, to help carry out these responsibilities and to improve the quality
of the compliance monitoring function.
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EPA ORDER 3500JL
6/29/88
d. Regional Administrators, The Regional Administrators are responsible
for:
(1) Implementing the requirements of this Order and Agency program
[Reference 4(d)] within their areas of jurisdiction, including periodically
evaluating implementation;
(2) Determining who in the Region is subject to this Order, and reviewing
and approving any exceptions to the training requirements;
(3) Ensuring in future contracts involving compliance inspections that
training is required by means of statements of work or other appropriate vehicles;
(4) Supporting in-house instruction for the Basic Curriculum, by
working with OECM to identify Regional personnel to serve as classroom instructors
and providing a Regional implementation plan by October 30, 1988; and
(5) Ensuring each program identifies States' inspector training needs
annually through the State/EPA Enforcement Agreements process; assisting States
in identifying ways to meet their training needs; and coordinating training oppor-
tunities.
e. Line Supervisors, Line supervisors in Program or Environmental
Service Divisions, are responsible for:
(1) Ensuring quality compliance inspections/field investigations using
performance standards, periodic appraisals, appropriate assignment to ensure
development, and recognition of personnel engaged in the compliai^j
monitoring function; and
(2) Identifying employees who require training, ensuring that employees
comply with the requirements of this Order, preparing requests for exceptions,
and maintaining records of actions.
f. Compliance Inspectors/Field Investigators. Compliance inspectors/
field investigators are responsible for:
(1) Advising their supervisor about the history and extent of relevant
training and experience, and assisting in the preparation of an Individual Develop-
ment Plan to meet the requirements of this Order; and
(2) Applying and maintaining the knowledge, skills, and techniques
acquired through training to ensure that inspections/investigations are
accomplished in a technically and legally sound manner.
A. James Barnes
Deputy Administrator
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AGENCY-WIDE PROGRAM TO
TRAIN, DEVELOP AND RECOGNIZE
COMPLIANCE INSPECTORS/FIELD INVESTIGATORS:
A PROGRAM DESCRIPTION
June 1988
U.S. Environmental Protection Agency
Washington, D.C. 20460
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DISCLAIMER STATEMENT
No language in EPA Order 3500.1 and/or this policy shall
create any right in any person to use this Order as a basis for
suit, or as a basis for defense, against EPA; it is intended as
notice solely for internal personnel administration and its terns
shall not inure to the benefit of any person who is not employed
by EPA. Nothing in EPA Order 3500.1 nor this policy shall affect
adversely admissibility of evidence offered by the United States
in any proceeding, or the competency of witnesses called by the
United States.
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ACKNOWLEDGEMENTS
This Program Description was prepared for the Agency-wide Work
Group on Inspector Training and Development by the Compliance
Policy and Planning Branch, Office of Compliance Analysis and
Program Operations, Office of Enforcement and Compliance
Monitoring (OECM). The overall project manager and principal .
author was Rebecca A. Barclay. Appendices D-l to D-9, Summaries
of Program-Specific Curricula, were prepared by the Program
Offices.
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TABLE OF CONTENTS
EXECUTIVE SUMMARY pp. i
I. INTRODUCTION 1-2
I. DEVELOPING AND EVALUATING QUALITY IN
COMPLIANCE INSPECTIONS AND FIELD INVESTIGATIONS 2-4
A. Performance Evaluation
B. Assessing Training Needs
C. Standing Work Groups
I. TRAINING AND DEVELOPMENT 4-16
A. Curriculum
B. Applicability
C. Requirements and Exceptions
D. Implementation of Training
E. Implementation Timetable
F. Delivery of Training to State/Local
Personnel
V. RECOGNIZING EXCELLENCE 16-17
A. Building Recognition into the Work
B. Supporting Professional Development
and Recognition
C. Enhancing Public Recognition
APPENDICES
A. DEFINITIONS
B. SUMMARY OF HEALTH AND SAFETY REQUIREMENTS
C SUMMARY OF BASIC INSPECTOR CURRICULUM
D. SUMMARIES OF PROGRAM-SPECIFIC CURRICULA
E. SUMMARY OF RECOMMENDED MULTI-MEDIA
(MULTI-PROGRAM) TRAINING
F. SUPPLEMENTAL TRAINING
G. ACCOUNTABILITY
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EXECUTIVE SUMMARY
EPA1s program to train, develop and recognize compliance
inspectors and field investigators does the following:
o Focuses on Quality Inspections, not just "training for
training's sake," by continuing to rely on the Performance
Management System and the first-line supervisor's judgment in
evaluating the field performance and the readiness of an
inspector to lead an inspection. Development of criteria for
quality inspection reports and Supervisors' Guides for assessing
training needs and requesting exceptions are new tools provided
for this purpose.
o Establishes Minimum Training Requirements Before Leading
Inspections. In the form of a Basic Inspector Curriculum
developed by OECM, and Program-Specific Minimum Curricula
developed by the Program Offices, with Regions' and States'
participation.
o Addresses a Broad Audience including EPA's new and experienced
inspectors and first-line supervisors, along with EPA's
contractors leading compliance inspections and field
investigations for compliance and enforcement-related purposes.
o Maintains Flexibility in Implementation by phasing in
requirements for new inspectors and all first-line supervisors on
October 1, 1989, and for experienced inspectors on October 1,
1991. The Program also allows exceptions to requirements based
on previous training and experience in most instances; however,
new inspectors cannot be excepted from the Basic Curriculum.
o Assists State/Local Personnel, by encouraging States to adopt
structured training programs for inspectors, sharing EPA
developed training materials, assessing training needs during the
State/EPA Enforcement Agreements Process, and offering to train
State instructors.
o Ensures Ongoing. Consistent Delivery of Training, by using
the EPA Institute model for the Basic Curriculum, continuing
contractor or grant support in program-specific situations, and
relying on a combination of these approaches to deliver
health and safety training required by existing EPA Orders.
o Maintains Program Accountability, by assigning responsibilities
for development, delivery, tracking and evaluation of training in
Headquarters and the Regions, establishing standing work groups
and incorporating evaluation throughout the program design.
o Builds Recognition into the Work by encouraging more feedback
and acknowledgment of the inspector's contribution to enforcement
actions and by encouraging AAs and RAs to reward excellence in
compliance monitoring inspections/field investigations.
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AGENCY-WIDE PROGRAM TO TRAIN, DEVELOP, AND RECOGNIZE
COMPLIANCE INSPECTORS/FIELD INVESTIGATORS ;
I. INTRODUCTION
In June, 1988, the Administrator issued a policy,
entitled, "Agency-wide Program to Train, Develop and
Recognize Compliance Inspectors and Field Investigators."
The primary goal of this program is to foster quality compliance
inspections and field investigations as critical components
of the Environmental Protection Agency's (EPA's) compliance
monitoring and enforcement functions.* It is the continuing
responsibility of the compliance inspector, or field invest-
igator, and his/her first-line supervisor to focus on
quality, not just quantity and timeliness in meeting the
commitments for inspections and investigations. Managers
and staff at all levels should support this emphasis throughout
the Regions and Headquarters.
There are existing systems and responsibilities which
EPA will continue to rely upon to ensure quality. Among
these are development and provision of inspection guidance
manuals, policies, and procedures; management systems
including performance standards and performance appraisals;
and decisions by the first-line supervisor on assignments
and the readiness of personnel to represent the Agency
in the field with the regulated commmunity. This document
explains several new actions designed to reinforce the goal
of quality in EPA's compliance monitoring programs and
details the responsibilites of Agency managers and staff in
carrying out these actions.
Highlights of these actions include:
o Using New Tools to Assess Inspectors/Investigators*
Training needs;
o Reinforcing Quality in Inspection Reports;
o Establishing Formal Training Curricula and
Requirements;
* Activities encompassed in the term compliance inspections/
field investigations are shown in "Definitions," Appendix A.
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o Creating Standing Work Groups to Improve EPA's
Compliance Inspection Programs; and
o Building Recognition into the Day-to-Pav Work.
Taken together these key actions should help create
the necessary conditions for high quality inspections,
thereby strengthening the Agency's compliance and enforcement
programs. The remainder of this document describes these
and related actions in more detail.
II. DEVELOPING AND EVALUATING QUALITY IN INSPECTIONS AND
INVESTIGATIONS
A first-line supervisor has very important responsi-
bilities regarding employee development. The supervisor
makes decisions on the individual's training needs, the
best ways to meet those needs, if and when an individual
is ready to lead an inspection, the annual performance
rating, and when promotions are warranted. These activities
are done cyclically and are very closely interrelated. To
assist supervisors with these responsibilities, the following
will occur.
A. Performance Evaluation
Training prerequisites alone do not ensure high quality
performance in the field. Nor is completion of these the
sole basis for a first-line supervisor to decide that an
employee is ready to lead inspections. Personal qualities
such as individual motivation and judgment are among the
factors a supervisor considers. EPA's Performance Managment
Systems provides the framework for assessing the individuals
readiness for leading inspections/investigations and the
quality of performance.
When evaluating the quality of performance of compliance
inspectors/field investigators, first-line supervisors are
strongly encouraged to use three primary methods with related
performance standards:
o Review of inspection plans., files and reports against
established criteria for quality; Criteria for evaluating the
quality of inspection reports should be developed in conjunction
with case development personnel and a system of periodic reviews
should be established that offers clear and prompt feedback.
Some programs and Regions already use this approach.
o Direct observation of the inspector's performance in the
field; Because inspectors operate independently in the field, it
is crucial for the supervisor to have direct knowledge of how the
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individual is performing in the field as EPA's representative.
Periodically observing and evaluating the inspector in the field
can be a useful way of developing such knowledge.
o Self-evaluation; Self-evaluation is always an important
component, so that the supervisor knows whether the inspector
understands what is important about quality in performance
and how the individual perceives his/her own accomplishments.
B. Assessing Training Needs
As part of this program/ Program Offices and OECM
are developing Supervisors' Guides to help supervisors assess
previous training and experience against the established
curricula. These guides will link the training curricula to the
knowledge, skills and abilities (KSAs) that are related to the
job. They offesr a common framework for applying training
requirements, annually reviewing training needs, preparing
Individual Development Plans, and requesting exceptions from
training requirements. These guides will be available during FY
1989.
Also Program Offices and OECM are encouraged to develop
and test objective measures to assess what individuals have
learned through the training program and to use this information
in deciding future training needs. Such measures of progress
could be self assessments built into training materials, mock
inspections or other means of evaluating learning.
C. Standing Work Groups
Standing work groups are important to support and promote
quality in all aspects of EPA's compliance inspection/monitoring
programs. These groups provide opportunities for discussion
among peers and can enhance the sense of professionalism among
the Agency's very diverse group of compliance inspectors and
investigators.
Program Offices will establish standing work groups composed
of Headquarters, Regional and State compliance inspectors/
investigators and other compliance program staff to exchange
ideas about work methods and strategies; to assist in design,
development and review of training materials; and to develop
better mechanisms for timely dissemination of information on
policy and regulatory changes related to inspections/
investigations. Program Offices have already used such groups
effectively in the development of the program-specific curricula
that form a central component of the training program described
below.
Related to this, the Program Offices should also establish
mechanisms to keep inspectors/investigators abreast of
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policy, regulatory, and procedural changes between training
cycles (i.e. newsletter, procedures memoranda, inspection manual
inserts).
Also, OECM will establish a board of Senior Agency Managers,
inspectors and investigators from Headquarters and Regions to
advise OECM in updating EPA Order 3500.1, overseeing and
implementing this program, updating the Basic Curriculum, and
developing other projects to improve the Agency's compliance
monitoring programs.
III. TRAINING AND DEVELOPMENT
The primary goal of the EPA's national training program is
to develop and maintain among EPA employees, the knowledge,
skills and abilities needed for high quality compliance
inspections on a consistent and continuing basis. EPA Order
3500.1 establishes formal curricula and minimum requirements
for all EPA inspectors, first-line supervisors of inspectors,
EPA contractors and others conducting inspections under EPA's
statutes. The Order also establishes procedures for exceptions
to the training requirements.
This is the first time the Agency has articulated a
national, comprehensive approach to professional development
of compliance inspectors. Program Offices and the Office
of Enforcement and Compliance Monitoring (OECM) are responsible
for developing and maintaining these training programs on a
continuing basis. Both the Regional Offices and Headquarters
Program Offices have important roles in delivering the training.
A. Training Curricula
The curricula consist of three required elements:
Occupational Health and Safety, Basic, and Program-Specific
Minimum Curricula. Appendices B, C, and D respectively describe
each curriculum. Recommendations on multi-media (multi-program)
training appear in Appendix E. Supplemental training to
strengthen skills such as negotiations and appearing as an expert
witness are also available, as described in Appendix F. For more
information about each curriculum, contact the representative
listed in each summary. Briefly these curricula are:
1. Occupational Health and Safety; EPA Orders 1440.2 and
1440.3 establish requirements for knowledge of hazard
recognition, personal protective equipment, and general health
and safety practices. The Occupational Health and Safety Staff
(Office of Administration and Resources Management) is
responsible for updating these Orders and the associated
curricula. (See Appendix B.) Training required by these Orders
is an essential component of the Basic Curriculum for inspectors.
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2. Basic Inspector Curriculum: This Curriculum establishes
required t- ining to provide a comprehensive overview of
knowledge and skills needed for compliance inspections/field
investigations under any EPA statute. It consists of a course,
that integrates legal, technical and administrative subjects,
with communication skills. The goal of this training is to
foster a common understanding of the role of the compliance
inspector and EPA's general enforcement philosophy; the
enforcement authorities and enforcement process under all the
major environmental statutes; and to develop skills needed to
gather information, collect evidence> and write objective reports
of findings. OECM is responsible for developing and updating
this course and overseeing implementation of the curriculum.
Appendix C describes the curriculum in more detail. The
curriculum also encompasses the training required by the Health
and Safety Orders cited above.
3. Program-Specific Curricula; Each Program Office has
defined a minimum curriculum of legal, programmatic, and
technical subjects to prepare an inspector to lead specific types
of inspections, recognize violations, and to properly obtain
information/evidence. The curriculum must be completed prior to
leading a inspection. Appendix D contains a brief summary of
each Program Office's minimum curriculum. If an individual is
leading inspections in more than one program area, s/he must
complete the minimum curriculum for each program area before
leading an inspection in that program.
Each Program Office has or will develop advanced or
specialized curricula for particularly complex or difficult types
of inspections, and will incorporate these into their training
plans as they are developed and approved by training work groups.
The proper mix of inspectors.with specialized.training is the
decision of Regional management, depending on needs for
specialized types of inspections and knowledge of control
technologies or industries.1 Any inspector seeking such
specialized training should have previously completed the Basic
and Program-Specific Minimum Curricula.
4. Multi-Media (Multi-Program) Training
The goal of multi-media (multi-program) training is
to develop a flexible, work force capable of responding to
changing program priorities and to enable more efficient
use of travel time and money. Regions are encouraged to support
1Throughout this document, wherever Regional Administrator
or Regional Management appears, the same authories or
responsibilities apply to any Assistant Administrator with
Headquarters-based compliance inspectors/field investigators,
for example, in the Air Mobile Sources Program.
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multi-media (multi-program) training where the relationship
between the requirements of two or more programs or the location
of the facilities makes it cost-effective to do.so. Appendix E
recommends areas for future development of multi-media (multi-
program) inspections and associated training.
5. Supplemental Training
To supplement the required Basic Curriculum, EPA
inspection personnel are encouraged to take other training
courses designed to strengthen specific skills associated with
the compliance and enforcement process, such as administrative
hearings/trials, negotiations skills, appearing as an expert
witness, and criminal enforcement techniques. See Appendix F
for additional information and whom to contact.
6. Refresher-Training
The purpose of refresher training for inspectors and their
first-line supervisors is to reinforce basic knowledge and
skills and to keep current the specific technical, legal
and programmatic knowledge and skill needed for high quality
inspections/investigations. Refresher training in occupational
health and safety is required annually under EPA Orders 1440.2
and 1440.3.
Refresher training in both the Basic and Program-Specific
Minimum Curricula is strongly recommended every three years at a
minimum. The first-line supervisor will determine the frequency
of such training based on the needs of the individual, and
changing emphases or needs in the Compliance Program. This means
that training is ongoing, rather than a one-time occurrence.
Program Offices may specify refresher training more frequently
for some or all parts of their curricula.
B. Applicability
This section elaborates on EPA-Order 3500.1, Section 2 so
that staff and managers implementing this training program for
compliance inspectors/field investigators have a broader
understanding of its applicability to EPA personnel, contractors
and others performing inspections under EPA's statutes, and to
State and local personnel.
1. EPA Compliance Inspector/Field Investigators, and First-
Line Supervisors.
The requirements of this program apply to all EPA compliance
inspectors/field investigators and the first-line supervisors of
individuals who lead or oversee compliance inspections/field
investigatons. While program requirements apply to both "new"
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and "experienced" personnel as defined in the Order, there are
some distinctions in training requirements and exceptions to
then. Regional Administrators and those Assistant Administrators
with inspectors based in Headquarters and are responsible for
determining which personnel fall in the categories of "new" and
"experienced," and which requireme-.tr and/or exceptions apply.
Although not required, anyone participating or assisting in
compliance inspections/field investigations is strongly
encouraged to complete the Basic and Program-Specific Curricula.
Not all individuals performing work as On Scene Coordinators
(OSCS) and Remedial Project Managers (RPMS) under the CERCLA
program are covered by the definition of the compliance
inspection/field investigation function. OSWER will develop
additional program guidance to assist Regions in distinguishing
these functions from other programmatic responsibilities.
2. EPA Contract Personnel and Others
In order to be effective representatives of EPA and carry
out Agency policies and procedures, EPA contract personnel,
consultants, and other personnel performing compliance
inspections/field investigations under EPA's statutes must
fulfill the requirements of the Basic and Program-Specific
Minimum Curricula prior to leading any inspections. Program
Offices and Regions, are responsible for assuring that under
future contracts and assistance agreements awarded under the
Senior Environmental Employment Program involving :-::.pliance
inspections, training is required by means of sta. ments of work
and/or other appropriate vehicles.
3. State/Local Personnel
Because State and local personnel perform more than 80%
of all environmental compliance inspections nationally under
delegated or approved programs, it is essential for EPA to
work with the State and local agencies to help assure that
their personnel too receive ample training and development.
Although this program does not require State/local agencies to
train compliance inspectors/field investigators, it does
encourage these agencies to adopt structured approaches to
train their personnel, recognizing State-specific concerns and
the value of alternate instructional methods, and to use EPA-
developed training materials where appropriate.
EPA recognizes that States' training needs differ from
EPA's needs in areas such as program requirements and
regulations, but there are common areas of need, for example in
technical field methods and investigative techniques. In many
instances, States are the repository of expertise that EPA needs
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8
to tap as well. EPA's training program recognizes the importance
of this mutual relationship in design and implementation of
inspector training (See discussion in Section III. F).
C. Requirements and Exceptions
The Basic and Program-Specific Minimum Curricula establish a
core set of subjects and field experience that must be completed
by each inspector. Regions are encouraged to tailor training
materials to suit local needs, while still being consistent
with the national program. This means that Regions may add
to the course content but coverage of the essential content
is required. Completion of any of the training required
under this program means completing self-study, OJT and/or
participation in classes covering the content of the curriculum.
Training requirements are oriented around key stages
in the process of employee development as follows:
1. Prerequisites to Field Activities
EPA Order 1440.2 established basic health and safety
training requirements that apply to all of EPA's compliance
inspectors/field investigators and their first line supervisors,
and that are prerequisites to any activities in the field.
The training requirements of EPA Order 1440.3 may also apply.
2. Prerequisites to Leading Inspections
EPA Order 3500.1 establishes minimum training requirements
under the Basic and Program-Specific Minimum Curricula for
all of EPA's compliance inspectors/field investigators that
constitute prerequisites to leading or overseeing inspections/
investigations performed by States/local personnel, EPA
contractors or others conducting inspections under EPA's
statutes.
3. Within One Year When Supervising
EPA Order 3500.1 establishes minimum training requirements
under the Basic and Program-Specific Minimum Curricula for
all first-line supervisors of personnel who lead or oversee
compliance inspections that should be completed within one
year of appointment to the supervisory position. If the first-
line supervisor directs inspectors/investigators in two or more
programs, the supervisor may need additional time to complete all
of the applicable Program-Specific Minimum Curricula, and should
do so as soon as practicable.
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4. Procedure for Exceptions
Paragraph 9 (d), EPA Order 1440.2 and EPA Order 1440.3
provide procedures that should be followed to seek exceptions
to health and safety training requirements. Paragraph 8 (c),
EPA Order 3500.1 establishes the procedure for obtaining
exceptions to requirements to complete the Basic and Program-
Specific Minimum Curricula. In the Regions, the responsibility
for approving exceptions rests with the Regional Administrator.
Delegation below this level may be made to the Deputy Regional
Administrator or a panel of managers, excluding the immediate
first or second-line supervisors of the individual for whom
an exception is being requested.
For those Program Offices with inspectors based in
Headquarters, the authority to approve requests for
exceptions for these individuals rests with the Assistant
Administrator. Delegation below this level may be made
to the Deputy Assistant Administrator, the Office Director, or in
the case of OECM, to the Director of NEIC. In no case does the
AA approve requests for exceptions made for personnel based in
the Regions.
5. Exceptions to Requirements for Completing Basic and
Program-Specific Minimum Curricula
Regional Administrators or Assistant Administrators, or
their delegatees, are responsible for determining whether each
inspector or first-line supervisor is "new" or "experienced"
as defined in EPA Order 3500.1.
The following chart (FIGURE 1) shows what options exist for
new and experienced inspectors/investigators and first-line
supervisors of inspectors to receive exceptions to these
requirements. These exceptions must be based on an evaluation of
each inspector's or supervisor's previous training and experience
as compared to the required curricula. The Supervisors'
Guides discussed in Section II. B are the primary tool for
performing this assessment.
For the Basic Curriculum, the policy of no exceptions for
new personnel is important because this training is the common
foundation on which the Program-Specific Minimum Curricula
builds. Exceptions for some experienced employees may be
appropriate. Nonetheless, experienced inspectors are strongly
encouraged to take the Basic Curriculum even if excepted from it
because it is useful as refresher training and allows them to
share experiences with new inspectors.
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1°
For Program-Specific Curricula/ a limited number of
exceptions are possible for both new and experienced employees,
based on previous training and experience. Supervisor's Guides
will provide criteria for such exceptions.
FIGURE 1. SUMMARY OF POLICY ON EXCEPTIONS
TO TRAINING REQUIREMENTS
BASIC
CURRICULUM
NEW
INSPECTORS/
INVESTIGATORS
AND 1ST-LINE
SUPERVISORS
EXPERIENCED
INSPECTORS/
INVESTIGATORS
AND 1ST-LINE
SUPERVISORS
NO
Exceptions
Possible
Limited Number
of Exceptions
Possible
PROGRAM-SPECIFIC
MINIMUM CURRICULUM
Limited Number
of Exceptions
Possible
Limited Number
of Exceptions
Possible
D. Implementation of the Training Program
In implementing the training program, the primary goal
is to develop and deliver, on a consistent and timely basis,
the necessary instructional materials and course offerings
required under the Basic and Program-Specific Minimum Curricula.
This section discusses key principles, responsibilities and
the timetable for developing and delivering this training
program to EPA personnel and assisting State/local personnel.
Appendix G contains a detailed list of functions and
responsibilities needed to make this program a success.
1. Design and Development of Training
Development of training involves the key functions of
defining the content, selecting the instruction method(s) and
developing the associated training materials. Design and
development of the Basic and Program-Specific Curricula and
the associated training materials are primarily functions
of Headquarters. The AA, Office of Administration and Resources
Management (OARM) is responsible for the Health and Safety
Curriculum, the AA, Office of Enforcement and Compliance
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11
Monitoring, for the Basic Curriculum, and the AA's, Program
Offices, for the Program-Specific Curricula. Key principles
for design and development are shown in Table 1. following.
Table 1.
KEY PRINCIPLES FOR DESIGN AND DEVELOPMENT OF TRAINING
1. Active participation by the Regions/States in
annual assessment of training needs, and in
development and evaluation of training materials
and methods.
2. Instructional value of training materials and
methods is apparent; inspection manuals are not
sufficient.
3. Evaluation of training (including objective mea-
sures or tools for self-evaluation, pre-and
post-training) is built into the materials and
methods, and results are used by Program Offices
and OECM to develop or revise training.
4. Training methods and materials are selected and
designed to maximize their replicability and to
minimize delivery costs to a wide audience in-
cluding State and local personnel, EP£ contract-
ors and others.
2. Delivery of Training
This section describes the general aproach to delivery of
the Basic Curriculum and the Program-Specific Curricula to EPA
personnel. Delivery means who receives what training, where and
how. Key principles appear in Table 2 following.
a. Balancing Flexibility with Effectiveness
Effective training depends on the instruction methods used
to convey the knowledge or techniques to be learned. OECM and
the Program Offices have identified the preferred method(s) of
instruction for their curricula, and have or will develop
materials accordingly. When classroom instruction is the
preferred approach, a continuing concern has been the
availability of classes. To accommodate this concern, EPA Order
3500.1 and the Program Description do the following:
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12
(1) Broadly define classroom instruction to include
seminars, workshops, lecture-type or video-assisted classes,
or question-and-answer sessions following prior independent
self-study, i.e. any approach that fosters group interaction
with an instructor or an experienced inspector.
(2) For the Basic Curriculum, the preferred approach is
classroom instruction broadly defined as noted above, because
of the benefits to be derived such as team-building within
the Region and interaction between more experienced and less
experienced inspectors. Reliance on in-house instructors to
implement this approach, under the EPA Institute, is the
preferred approach; however, contractor support may be
considered.
(3) Program-Specific Curricula, in deference to different
State approaches which rely more heavily on OJT, sometimes leave
the instructional method optional while expressing a preference
for classroom experience. Program Offices will work to
provide training materials in flexible formats to accommodate
these differences.
b. Regional responsibilities include:
(1) The Regional Administrator is responsible for planning
and organizing delivery of the Basic Curriculum in the
Region, relying on in-house instructors for any classroom.
training. The Region should submit a written plan for this
to OECM by'October 30, 1988. (See Appendix G for a more
detailed list of responsibilities.)
(2) For supervised self-study, the first-line supervisor
is responsible for ensuring that each inspector has the
necessary materials, and for on-the-job training, that
necessary field assignments under the supervision of an
experienced inspector are given.
(3) Regions must absorb the costs of course materials,
course attendance, travel for training of instructors or
attendance at courses in another Region, and in rare instances,
at Headquarters.
c. Headquarters responsibilities include;
(1) For the Basic Curriculum, OECM is responsible for
working with Regions, the EPA Institute (OARM) and Program
Offices with inspectors based in Headquarters, to assure
consistent and continuing delivery. OECM will maintain a list of
trained instructors from both Headquarters and other Regions who
will be available to supplement Regional instructors. Each AA
with inspectors based in Headquarter* is responsible for planning
delivery of the Basic Curriculum a- hov\d submit a written
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13
plan for thi- to OECM by October 30, 1988 (may coordinate among
Program Offices or the Region.)
(2) For Program-Specific Curricula, the Program Offices are
responsible for assuring delivery occurs on a continuing
basis by a) assigning responsibilities for training delivery to
specific managers and staff, b) providing training contracts
for delivery and support, and/or c) providing grants to
university training centers or other nonprofit organizations to
deliver training, as appropriate.
Table 2.
KEY PRINCIPLES FOR DELIVERY OF TRAINING
1. To the greatest extent possible when using class-
room training, rely on in-house instructors for
delivery of the Basic Curriculum in the Regions
and Headquarters. When using on-the-job train-
ing, rely on in-house experienced inspectors
as trainers.
2. For Program-Specific Curricula, continue to
rely on contractors or grants to non-profit
organizations to deliver training on an
ongoing basis.
3. Coordinate and communicate training schedules
early between Program Offices and the Regions,
and between the Regions by using up to date
electronic systems.
E. Implementation Timetable
1. Phasing of Training Requirements
Although EPA Order 3500.1 is effective on the date of
issuance, the Program Offices and Regions need time to complete
materials, organize delivery of training, set up any
administrative systems, identify who needs to be trained,
and evaluate qualifications for exceptions. Recognizing
these steps will take time, the Order should be fully
implemented for new inspectors by October 1, 1989, and
.for experienced inspectors by October 1, 1991, as shown in
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14
Figure 2. After these dates, neither new nor experienced
inspectors nay lead inspections unless they have completed
required training or have been excepted from the requirements.
Beginning October 1, 1989, first-line supervisors, must
complete training requirements within one year of appointment to
the supervisory position. Those supervisors who direct
inspectors/investigators in two or more programs may need
additional time to complete all of the applicable program-
specific minimum curricula and should do so a soon as
practicable.
EPA Order 3500.1 states that a "new" inspector is any
inspector hired or transferred subsequent to the issuance
date of the Order. In the interim between the issuance date
(June 1988) and full implementation (October 1, 1989), these
employees are still subject to the requirements and exceptions
applicable to "new" inspectors. Even though they are gaining
experience, they do not convert to the "experienced" inspector
category; and they may not be excepted from the Basic Curriculum.
FIGURE 2. PHASING IMPLEMENTATION OF
TRAINING REQUIRED BEFORE LEADING AN INSPECTION
After this date After this date
New Inspectors Experienced Inspectors
Order cannot lead unless cannot lead unless
Issued training require- training requirements
ments are fulfilled, are fulfilled.
Supervisor's (10/1/89) (10/1/91)
Guides
Available
Pilots*
Completed
I I I I
6/ 10/ 12/ 10/ 10/ 10/
88 88 88 89 90 91
CALENDAR YEAR
*Pilots of the Basic Inspector Curriculum and Inspector Health &
Safety Module.
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15
2. Availability of Training Materials
Not all the training materials for Program-Specific
Minimum Curricula vill be available with sufficient time
before requirements must be met. This should not delay the
implementation of the training requirements. Each Program Office
vill identify what materials are available in the interim.
Program and Regional managers should use these existing
materials to cover the subject matter of the Program-Specific
Minimum Curricula.
When the preferred, new training materials or guides for OJT
become available under the Program-Specific Minimum Curricula,
compliance inspectors/field investigators shall have one
year thereafter to complete the training associated with
the material or be excepted, if eligible.
F. Delivery to State and Local Agency Personnel
State and local personnel are a substantial part of the
audience for inspector training, because they conduct the
vast majority of compliance inspections in support of
"ederal environmental statutes through delegation or author-
ization. Although EPA Order 3500.1 does not establish
requirements for any of these personnel, EPA will share training
materials (and training of State instructors where appropriate)
and encourages State and local agencies to adopt structured
approaches to train compliance inspectors/field investigators.
EPA encourages participation by State and local pex> mnel in
available EPA course offerings, development and use of
better structured on-the-job training, and the use of
self-study materials with apparent instructional value.
To promote training of State and local agency personnel,
Regions, Program Offices will:
o Encourage adoption of structured State/local
inspector training programs through information
sharing and participation in EPA's own curriculum
design, and promote cooperative State ventures
in cost-efficient training, such as that offered
under the Northeast Hazardous Waste Project.
o Assess States' training needs annually through the
State/EPA Enforcement Agreements process, and during
mid-year reviews identify priorities for training.
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16
o Establish the means to routinely communicate about
course offerings by Program Offices and their training
contractors to State and local personnel.
o Offer to train State instructors in how to use training
materials developed by EPA, who can then train
other State/local employees on cite.
o Identify individuals with expertise within EPA and within
State and local agencies to tap as trainers.
This approach allows State and local agencies wide
latitude to devise training programs appropriate to their
own circumstances while drawing on relevant training
materials available from Regions, Program Offices and OECM.
Achieving better recognition of the crucial role that
EPA1s compliance inspectors/field investigators play as the
front line of the enforcement programs is another important
aspect of the inspector training and development program.
Further steps to enhance recognition include building
recognition into the work, supporting professional develop-
ment and enhancing public recognition.
A. Building Recognition into the Work
Striving to increase recognition in the day-to-day
interactions between inspectors/investigators and enforcement
personnel and to better use EPA's existing awards system
are important as outlined below:
1. Routinely following through to recognize the inspector's
work in support of the enforcement response using letters
of commendation and appreciation where appropriate, at all
levels of Regional and Headquarters management.
2. Working with the EPA Institute to organize an annual
meeting or other forum to recognize the in-house instructors
for the Basic or Program-Specific Curricula.
3. Strongly encouraging AA or RA recognition of the
compliance monitoring function, using the existing merit and
honor awards system. OECM will work with the AAs or RAs to
issue joint awards for excellence in the compliance monitoring
function.
4. OECM, with its Advisory Committee, will identify
opportunities for using existing awards to recognize compliance
inspectors/field investigators for such activities as:
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17
(a) Outstanding contribution to a major case by means
of high quality inspection/investigation, report
and overall technical support given to a case;
(b) Introducing new field techniques or methods; and
(c) Improved means of reporting compliance status.
B. Supporting Professional Development and Recognition
EPA endorses membership by inspectors/investigators in
societies and associations which have objectives appropriate to
the inspector acquiring and maintaining knowledge, skills or
professional standing of importance to the mission of the Agency.
Inspectors are encouraged to 1) assume leadership roles in job-
related professional societies and associations, 2) support
publications which deal with fields of knowledge important to the
Agency's mission, and 3) participate in professional society
meetings.2 Program Offices and Regions are encouraged to support
these activities with travel funds as appropriate.
C. Enhancing Public Recognition
Program Offices, Regional Administrators and OECM are
encouraged to publicize compliance monitoring and inspection
functions and excellent performance of those functions through
existing and new publications such as the EPA Management News
and the EPA Journal.
2Thomas, Lee M. Memorandum entitled, "Policy on Participation
in Professional Societies and Associations.11 USEPA.
November 26, 1986.
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APPENDICES A - G
June 1988
U.S. Environmental Protection Agency
Washington, D.C. 20460
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SUMMARY OF APPENDICES
A. DEFINITION
B. SUMMARY OF HEALTH AND SAFETY TRAINING ORDERS
C. SUMMARY OF BASIC INSPECTOR CURRICULUM
D. SUMMARIES OF PROGRAM-SPECIFIC CURRICULA
E. SUMMARY OF RECOMMENDED MULTI-MEDIA
(MULTI-PROGRAM) TRAINING
F. SUPPLEMENTAL TRAINING
G. ACCOUNTABILITY
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APPENDIX A
DEFINITIONS
The definitions in this appendix are quoted from
EPA Order 3500.1, "Training and Development for Compliance
Inspectors/Field Investigators," issued June 1988. The
numbering and lettering is identical to the Order.-
5. DEFINITIONS.
a. Compliance Inspection/Field Investigation Function
The function includes leading, or overseeing State/local,
contractor or other personnel conducting, any of the following
activities fot the purpose of establishing the compliance status
of facilities or sites with applicable laws, standards,
regulations and permits and/or of supporting appropriate
enforcement action (administrative, civil judicial or criminal),
including:
(1) planning and carrying out inspections of pollution
abatement equipment, relevant facility operations and maintenance
practices, self-monitoring practices and records, and laboratory
equipment;
(2) gathering and developing evidence, including but not
limited to emission monitoring measurements, other analytical
field procedures such as sampling and the associated quality
assurance procedures, and in depth engineering evaluations; and
(3) maintaining field logs, recording field observations
photographically, analyzing sampling and emissions data, and
preparing reports of observations along with any supporting
documentation.
Any EPA employee performing these activities regardless of
job title shall be considered a compliance inspector/field
investigator for the purposes of this Order. The terms
compliance inspector/field investigator will be used throughout
this Order. This function does not include field activities or
investigations for purposes such as research and development
which are unrelated to compliance monitoring or enforcement.
Not all individuals performing work as On-Scene Coordinators
(OSCs) and Remedial Project Managers (RPMs) under the CERCLA
program are covered by the definition of the compliance
inspection/field investigation function. Additional program
guidance will be developed to assist Regions in distinguishing
these functions from other programmatic responsibilities.
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b. New Compliance Inspector/Field Investigators. Including:
(1) Individuals newly employed by EPA subsequent to the
issuance date of this Order regardless of previous training in
and experience leading environmental compliance inspections/field
investigations, or
(2) Individuals rehired by EPA or transferred within
EPA, subsequent to the issuance date of this Order, with no
previous training in and experience leading environmental
compliance inspections/field investigations.
c. Experienced Compliance Inspectors/Field Investigators.
Including: Individuals who were employed by EPA on the issuance
date of this policy, and/or who have previous training in and
experience leading environmental compliance inspections/field
investigations in any one of EPA's compliance and enforcement
programs.
d. First-line Supervisors of Inspectors. A first-line
supervisor is the immediate supervisor of the day to day work of
the inspector/investigator who leads or oversees compliance
inspections/ field investigations. The first line supervisor,who
is responsible for the official performance appraisal, may
be"new" or "experienced" as defined above in items 5(b) or 5(c).
e. Contract Inspectors and Others. This category includes
contract personnel and employees of a grantee organization under
the Senior Environmental Employment Program performing compliance
inspections/field investigations under EPA's statutes.
f. Leading an Inspection. Leading an inspection means
independently conducting a compliance inspection/field
investigation or directing an inspection/investigation with
others as support staff.
g. Curriculum. Curriculum refers to defined content
presented in a sequence of supervised self study, formal
on the job and/or classroom training:
(1) Supervised Self-Study. Self study means any
knowledge gained through independent, personal study, and
overseen by a first line supervisor or an experienced
inspector/investigator.
(2) On-the-Job Training. On the job training (OJT)
means structured training that relates principles or theories
to work related skills which are demonstrated and applied in
the field environment during an actual compliance inspection/
field investigation.
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(3) Classroom/classes. This refers broadly to any
form of instruction, flexible in format and size, to include
seminars, workshops, lecture-type or video-assisted classes,
or question and answer sessions following prior independent
self study, i.e., any approach that fosters group interaction
with an instructor or an experienced inspector.
h. Completing Required Training. Completion of required
training means completing self-study, OJT and participation in
classes covering the content described in applicable training
curricula.
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APPENDIX B
SUMMARY OF EPA ORDERS ON
HEALTH AND SAFETY TRAINING OF FIELD EMPLOYEES
A. SUMMARY OF EPA ORDERS 1440.2 AND 1440.3
EPA compliance inspectors and field investigators continue
to be subject to the training and other requirements of EPA
Order 1440.2 - Health and Safety for Employees Engaged in
Field Activities, and EPA Order 1440.3 - Respiratory Protection.
Pertinent portions of these Orders are summarized below.
For more complete information, refer to the Orders themselves
and/or contact the Occupational Health and Safety Designees
in the Reporting Unit (Headquarters or Regional Office) or
the Director, Occupational Health and Safety, Office of
Administration, U.S. Environmental Protection Agency, PM-273,
Washington, D.C. 20460 (FTS 8-382-3640).
1. EPA Order 1440.2 - Health and Safety for Employees in^
Field Activities fJulv 12. 1981)
a. Policy; Employees may not engage in routine field
activities until they have been trained and certified to a
level commensurate with the degree of anticipated hazards.
b. Training Requirements for Certification;
Basic 24 hours classroom training followed by ' ree days
level: of supervised field experience. Classroom subjects
include employees rights and responsibilities;
nature of anticipated hazards; emergency help and
self-rescue; vehicles - mandatory rules and
regulations; safe use of field equipment; use,
handling, storage, transportation of hazardous
materials; personal protective equipment/clothing, use
and care; safe sampling techniques.
Inter- 8 hours additional classroom training followed by three
mediate days of supervised field experience. Classroom subjects
level: include site surveillance and safety plan development;
use and decontamination of totally enclosed personal
protective clothing and equipment; use of field test
equipment for radioactivity, explosivity.
Advanced 8 hours additional classroom training followed by three
level: days of supervised experience. Required for employees
who manage field activities at sites involving
hazardous materials. Classroom subjects include
management of restricted and safe zones; rules for
handling the press and VIPs; and safe use of
specialized sampling equipment.
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Refre- At all levels, a minimum of 8 hours refresher classroom
sher instruction is required annually.
c. Exceptions to Training Requirements; The- Director of
Occupational Health and Safety can certify an employee based
on an evaluation of previous training, education, and experience.
Recommendations for- this type of certification are made by
the Occupational Health and Safety Designee at the employee's
Reporting Unit.
2. EPA Order 1440.3 - Respiratory Protection fJulv 24. 1981)
a. Policy; EPA shall provide certified respiratory protective
devices, and employees shall use these devices whenever
necessary to protect their health due to the nature of the
working environment.
.b. Training Requirements; A minimum of six hours of initial
training and two to four hours refresher training annually is
to be provided to employees using respiratory equipment. The
training can be part of occupational safety and health training
for other reasons, and can count as credit for both programs.
Training topics include instruction in the nature of hazards;
explanation of the need for respirators; selecting the proper
respirator for the particular .purpose; capabilities and
limitations of the device; instruction and training in actual
use, including fit and seal testing.
B. TRAINING MATERIALS AND SOURCES
1. Non-EPA Training
There are many health and safety courses available from
public and private sources. The Occupational Health and
Safety Staff (OHSS( in Headqu?rters will review and approve the
content of such courses to meet: the requirements of 1440.2
and 1440.3.
2. EPA-Developed Training
EPA has also developed health and safety training courses
for all employees who engage in field activities. For more
information, contact the person or organization listed below
each course, or consult the Regional Health and Safety Manager to
determine which course is. suitable and satisfies applicable
training requirements under 1440.2 or 1440.3
a. OHSS-Developed Courses
(1) Basic Field Activities Safety Training (HazTrainj
(2) Safety and Health in EPA Field Activities (Steere &
Associates, Inc.)
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(3) Health and Safety Training for Compliance Inspectors
(Developed by OECM. Available FY 89)
Contact:
Regional Health and Safety Manager
or
Cherie demello-Zieschang
Occupational Health and Safety Staff
Office of Administration
U.S. Environmental Protection Agency
401 >i Street, S.W. (PM-273)
Washington, D.C. 20460
FTS: 8/382-3650
Commercial: 202/382-3650
b. .fice of Emergency and Remedial Response fOERR)
Developed Courses
(1) Hazardous Materials Incident Response Operations
(Course #165.5)
(2) Personnel Protection Safety Training
(Course 1165.2)
Contact:
Superfund Training Regional Contact
or
Registrar, OERR Training Program or
Thomas C. Sell, Training Coordinate or
Jerome Joyce, Training Officer
U.S. Environmental Protection Agency
26 West St. Clair Street
Cincinnati, OH 45268
FTS: 8/684-7537
Commercial: 513/569-7537
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APPENDIX C
SUMMARY OP BASIC INSPECTOR CORRICULOM
Basic Inspector Curriculum
The Basic Inspector Curriculum encompasses five subject
areas needed for safe and effective conduct of compliance
monitoring inspections in all EPA program areas. Health and
safety, one of these key subjects, is covered separately in
Appendix B preceding.
A. Basic Training Course
The basic training course, covering the fundamentals of
environmental compliance monitoring inspections, integrates key
concepts and procedures from four subject areas and presents
these through a combination of classroom and self'study methods.
In addition,' the curriculum explains EPA's enforcement
philosophy, the role of inspectors and compliance monitoring in
the administration and enforcement of environmental laws, and the
partnership between EPA and the States in assuring compliance,
particularly what is involved in oversight inspections with
States.
Legal Includes overview of EPA's major environmental
Authorities statutes and enforcement authorities, the admin-
Requirements istrative and judicial enforcement processes,
collecting and documenting evidence for
enforcement proceedings, authority and require-
ments for lawful entry.
Technical Includes types of inspections, inspection site
Skills and selection, and pre-inspection planning and
Procedures preparation, recognizing and documenting
violations, sample collection and handling,
and overview of protocol and procedures for
oversight inspections.
Communi- Includes gaining entry, inspector as educator,
cations interviewing techniques, negotiations, and
preparation of inspection reports.
Administra- Includes pay administration, timekeeping, leave,
tive travel, and procurement.
Procedures
B. Health and Safety Training
The Basic Inspector Curriculum encompasses training required
in health and safety procedures and respiratory protection under
EPA Orders 1440.2 and 1440.3, respectively. They describe levels
of required training depending on the type of field work to be
performed.
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C. TRAINING MATERIALS AND SOURCES
1. Basic Training Course
The course is designed in modular units that can be
presented either over a several-day sequence of time or in
individual units by in-house , experienced compliance and
enforcement staff.
Contact: Donna Fletcher
Compliance Policy and Planning Branch
. Office of Enforcement and
Compliance Monitoring
U.S. Environmental Protection Agency
401 M Street, S.W. (LE-133)
Washington, D.C. 20460.
FTS 8-382-7550; E-mail code EPA 2281.
2. CERCLA Basic Training (OSWZRl
The Office of Solid Waste and Emergency Response is
developing a tailored basic course for On Scene Coordinators and
Remedial Project Managers which will be available in FY 1989.
Contact: Division Director
CERCLA Enforcement Division
Office of Waste Programs Enforcement
401 M Street, S.W. (WH-527)
Washington, D.C. 20460
FTS 8-382-4810; E-mail code EPA 5240
3. Health and Safety Training
Appendix B describes EPA-developed courses and materials
that are available to satisfy the health and safety training
requirements.
Contact: Regional Occupational Health and Safety Manager
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APPENDIX D
SUMMARIES OF PROGRAM-SPECIFIC TRAINING CURRICULA
Program-Specific Minimum Curricula
The Program-Specific Curriculum for each major environmental
program prepares inspectors/investigators to lead specific
types of inspections/investigations and to obtain information and
evidence in a technically and legally sound manner. The minimum
curricula can be implemented quickly and will undergo periodic
changes based on course evaluations and needs assessments.
Although some specialized curricula are available, Program
Offices will be developing materials over the next few years.
The need for specialized training will be determined by the
first-line supervisor in consultation with the employee. In
general, any inspector seeking such training should have
completed the Basic and Program-Specific Minimum Curricula or
their equivalent before taking specialized training.
Summaries of the curricula for the following programs are
found in Appendix D:
D-l. Air-Stationary Sources
D-2. Air-Mobile Sources
D-3. Comprehensive Environmental Response, Compensation and
Liability Act (CERCLA)
D-4. National Pollutant Discharge Elimination System
(NPDES) .
D-5. Pesticides/Toxic Substances
D-6. Public Water Supply Supervision
D-7. Resource Conservation and Recovery Act (RCRA)
D-8. Underground Injection Control (UIC)
D-9. Wetlands Protection
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APPENDIX D-l
AIR STATIONARY SOURCE INSPECTOR TRAINING PLAN
EXECUTIVE SUMMARY
Objectives and Scope of Inspector Training Program
The Air Stationary Source Inspector Training Program
establishes a multi-level training curriculum for Agency
personnel engaged in stationary source compliance inspections. A
description of the training curriculum is presented in the
Inspector Training Plan (ITP). The two major objectives of the
program are: 1) to ensure that every inspector gains the ability
to conduct a Level II inspection within six-to-eighteen months of
the initiation of training and 2) that experienced personnel have
the opportunity to take advanced courses in their area of specia-
lization to upgrade their skills and continue their professional
development.
The ITP focuses mainly on entry level training for new or
inexperienced inspectors to ensure a minimum level of expertise.
The training curriculum graphically depicted in Figure 1 shows a
progressive sequence of core courses, self-study and on-the-job
field training (OJFT) designed to provide the essential technical
skills and procedural knowledge needed to conduct routine
inspections of all but the most complex source categories.
The training program is structured around three levels of
training. The first training level, referred to as generic-
basic, provides basic inspection knowledge and skills, common to
any Agency inspection function. The second training level,
termed program-minimum, provides those program-specific knowledge
and skills needed to conduct meaningful inspections of a wide
range of regulated air pollution source categories. The third
level of training consists of advanced specialized technical
training for more experienced inspectors to enable them to
perform highly complex inspections and compliance evaluations in
certain source-specific inspections areas. Although the current
training plan emphasizes entry level training (basic and program-
minimum) , the plan will be expanded in the next phase to include
more program-specialized training and various training paths for
attaining more advanced inspection skills needed to perform Level
III and IV inspections and special engineering knowledge needed
to work more proficiently in certain types of sources.
Training Sequence and Completion Time
The training sequence for the generic-basic and program-
minimum level courses is designed to be completed in six to
eighteen months. The exact completion time depends on the amount
of the time that the new inspector spends on training activities
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and the educational background and prior relevant experience of
the inspector. The chart shown in Figure 2 illustrates the
approximate training time required for new employees without
prior field experience. The chart assumes completion of the
prescribed basic courses within nine months and the program-
minimum courses within eighteen months. Many elements of the
generic-basic training and the program-minimum training occur
simultaneously as was shown on the time-line in Figure 1.
However, EPA Health and Safety rules require that certain safety
courses must be completed before the inspector can perform any
field work other than supervised participation in field training
demonstrations.
The training curriculum described in the ITP and outlined in
Figure 1 consists of at least 11 major training modules and is
estimated to require a total of 325 to 350 hours of course work
to complete. This is approximately 15 percent of the inspector's
available work time over an 18 month period. Compressing the
training schedule into a six month period, an option shown in the
training plan, will increase the percent time in-training to more
than 50 percent when averaged over the shorter time period. EPA
field supervisors, as a whole, strongly favor the accelerated
training option and are inclined to have new inspectors spend the
maximum time possible in training during their first few months
to prepare them to perform independent inspections and begin
contributing to the inspection workload at the earliest date.
Evaluating Training Needs and Developing Individual Training
Plans
The training program includes provisions for waiver of
certain program-minimus courses if the supervisor determines the
inspector already has the specific technical knowledge or skills
based on the employee's formal education and/or prior field
experience. A Supervisor's Training Evaluation Guide is being
prepared to assist supervisors in assessing the individual
inspector's training needs. After completing the generic-basic
portion of the curriculum which must be taken by all inspectors
without exception, each trainee would be evaluated to determine
any strengths, weaknesses or other critical gaps in the
inspector's education or experience background in order to
prepare an individual employee training plan. A supervisor's
decision to waive any of the prescribed program-minimum training
courses must be reviewed at a higher management level.
Training Delivery Methods
The training approach presented in the ITP advocates three
basic methods of training: 1} classroom courses, 2) formal on-
the-job field training, and 3) monitored self-study. A mix of
each type of training should be used depending on the most cost-
-------
effective training delivery method for a specific subject area.
Some factor possibly affecting selection of the training
delivery method and source of training can be readily antici-
pated. First, other than during the initial start-up of the
training program, only small groups of inspectors will need to
take a given course at a time. Second, classroom courses must be
given frequently in order to move new inspectors rapidly through
the program. Also, Agency travel budgets will likely not allow
for extensive travel to training courses held outside the program
operation area.
These factors strongly suggest that each Region should
develop good in-house training capability if the long-term
inspector training program is to operate efficiently and cost-
effectively. Therefore, instructor training will be included in
the training program and development of in-house training
capability will be encouraged.
Implementation of the Training Program
Many of the core training courses described in the ZTP are
not available at this time. Existing air training courses and
specialty compliance training workshops cover many of the topics
included in the proposed program-minimum curriculum and can be
used on an interim basis to implement the training program.
However, the training materials were generally developed for
other purposes and are not necessarily geared towards entry level
inspectors. Zn addition, the materials are not sufficiently
integrated with the other proposed training courses to offer a
thorough, well structured training experience or streamlined
enough to allow for completion of the training sequence in an
optimum timeframe.
Therefore, included as an integral part of the ITP is a
multi-year training development effort that will provide the
training curriculum envisioned in the plan. The 3 to 4 year
phased development schedule described in the ITP will permit work
to begin immediately on the training areas of highest need and
gradually fill-in and upgrade course modules as resources become
available. A summary of the training development projects
appears in Table 1.
Extending Training to State/Local Agencies
The Agency inspector training and development program
initiative is basically intended to apply to EPA compliance
inspectors. However, it is recognized that State and local
personnel conduct the vast majority of compliance inspections
nationally under delegated or approved State programs and that
they require comparable training to perform their inspection
duties.
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The State and local control program officials consulted
during development of the Air Stationary Source Inspector
Training Plan expressed interest in adapting EPA's inspector
training courses for their own training purposes. Therefore, in
the design and development of the Air Stationary source Inspector
Training Program every effort vill be made to develop training
materials that vill have the widest possible application to all
agency inspection programs. States will be welcome to use all
relevant training materials and to participate whenever possible
in training opportunities arranged by the Regional Offices.
To assure that the training program is fully responsible to
the training needs at both the Federal and State/local program
level and to have the widest outreach and benefit to all control
agency inspection personnel, a Training Advisory Group has been
established to provide input throughout the planning and
implementation of the program. Experienced compliance program
staff from EPA Regional Offices and State/local agencies have
been asked to serve as representatives. Their input is reflected
in the present plan.
Responsibility for Inspector Training
The Air Stationary Source Inspector Training Program cannot
be successful unless it has the assistance and support of all the
various air program offices involved in the planning, direction
and the daily operation of the Agency's air compliance inspection
activities. Responsibility for several of the more important
elements of the training program is discussed in the IIP.
The Regional Program Supervisors have ultimate responsi-
bility for assuring that inspector staff are properly trained and
equipped to perform their inspection duties. The first-line
supervisors, in particular, will play a critical role in actively
working with each inspector to identify training needs, prepare
individual training plans and monitor the training.
The ITP emphasizes the field training portion of the
curriculum as much as the classwork. The Regional Offices will
have the responsibility for developing a structured on-the-job
field training (OJFT) program and selecting and training OJFT
instructors. Although various training delivery options are
available it appears the most practical approach for the Regions
is to develop a cadre of qualified in-house instructors for
presenting all of the basic generic and many of the program-
minimum courses. The Regional Offices will also need to
designate persons to serve as focal points and coordinators for
implementing the program.
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The Stationary Source Compliance Division (SSCD) will serve
as the lead office for planning and coordinating the national air
inspector training effort. The Manpower and Technical
Information Branch of the Xir Quality Management Division (Air
Pollution Training Institute) will provide logistic support and
assist SSCD in the program planning and development. These
functions will include developing and updating the program
specific training curriculum, providing sufficient training
materials to do the training, conducting surveys of training
needs, coordinating the Air Training Advisory Group,, and
developing longrange training plans and supporting budget
requests.
Most of the generic-basic training courses will be developed
by the Office of Enforcement and Compliance Monitoring (OECM).
OECM will provide instructor guides and up-to-date training
manuals and other instructional materials heeded to carry out the
basic training. OCEM also has agreed to coordinate and oversee a
3-year Agency-wide evaluation of inspector training with the help
of the media programs.
Annual Assessment of Training Needs
The Stationary Source Compliance Program curriculum may
undergo changes fairly rapidly since it is a dynamic, technically
complex program that deals with a wide variety of emission
control regulations and regulated sources categories. To be
responsible to new and emerging compliance inspect-'on demands,
provisions are included in the ITP for developing new courses and
for periodic revision and updating of existing courses. This
will be accomplished through annual training needs surveys and
assessments, review of the training modules each year to correct
and replace out-of-date material, coordination with the program
offices on new control programs and regulations, and contact with
other EPA training groups and outside organizations.
Additional Information
For additional information contact: Division Director.
Stationary Source Compliance Division, Office of Air Quaility
Planning and Standards. 401 M Street, S.W., (EN-341) Washington,
D.C. 20460. FTS 8-382-2807.
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o
UJ
Nl
O
UJ
0.
VJ
a
o
Eeriest Sun Oaf*
Program Speciaflied Training
"\
. M*afth and Safety Refresher (400)
SpedelTy Course I
Specially Course?
HA-,-
o
o
Pofluftan Source*. Control, and ftoguMom (310)
CompDanc* Mor
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100
_ 80-
60-
o
O
o
40-
2
20-
LE6ENO
Orvttw-Job Fteld Training
Self-lnstnjctionil
Classroom
Latest
Completion
Date
Generic
Basic Training
Latest
Completion
Date
Program
Minimum Training
3-6
6-9 9-12 12-15 15-18
Time Since Employment (Months)
18-21
21-24
Figure 2. Training Time Requirements for New Employees without Prior Field Experience
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. Table 1.
Training Development Projects
First Phase (Current fiscal year through 1989):
Agency/Air Programs Orientation Course
Basic/Program-minimum Safety Course Series
Asbestos Inspection Safety Procedures
VOC Surface Coating Industry Training Package
VOC Fugitive Source Inspection
VZ/Opacity Enforcement Instructors Training Package
Combustion Source Compliance Evaluation
Environmental Statistics Review Course
Second Phase (FY 1989-1990):
Solvent Cleaning and Solvent Storage/Handling Facilities Insp.
Air Pollution Sources, Control and Regulations
Process Emission Capture and Gas Handling Systems
Emission Monitoring and Testing
VOC Inspection Safety Procedures
Third Phase (FY 1991-92):
Modifications to Program-minimum Courses
NESHAPS Organic Emission Standards and Air Toxics.Source
Inspection/Evaluation Procedures
Class B VOC Source Compliance Monitoring and Evaluation Tech.
Solid and Liquid Waste Incinerators Inspection and Performance
Evaluation
Source Permit Drafting Techniques to Support Inspection
Program Activities
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APPENDIX D-2
SUMMARY OF AIR - MOBILE SOURCE
INSPECTOR TRAINING PROGRAM DESCRIPTION
A. SUMMARY
The Air-Mobile Source Inspector Training Program establishes
a core program of self-study, coursework, and on-the-job training
(OJT). The Program training is intended for agency and non-
agency inspectors, the latter consisting of contractor, state and
local personnel who perform inspections as official representa-
tives of the' Agency. The purpose of the training is to develop a
knowledgeable and effective field investigative staff who
understand the goals of the mobile source enforcement program,
the investigative techniques and data necessary to develop solid
enforcement cases, and the program's underlying policies.
This summary describes a series of basic skills that should
be acquired and relevant training/methodology oriented to the
type of inspections, i.e., Level I, II, or III conducted by the
Program. The training that is basic to all levels of inspections
is shown first, followed by skills and training that are unique
to the different levels of inspection. There is no established
time frame for delivery; training is done on an as needed.basis.
Figure 1 below shows the plan in summary fashion. To obtain
a copy of the complete "Office of Mobile Sources Trogram Specific
Inspection Training" contact: Richard Ackerman, Field Operations
and Support Division, Office of Mobile Sources (EN-397F), USEPA,
401 M Street, S.W. Washington, D.C. 20460. FTS 8-382-2643.
FIGURE 1
General Training for All Levels
Basic Skills Training/Methodology
knowledge of EPA mission and general Self-study
Clean Air issues
Knowledge of applicable regulatory Self-study, classroom
requirements and statutory provisions (Colorado State Univ.
and/or Univ of MI
course)
Ability to recognize violations of Classroom (EPA
applicable provisions lecture), OJT-24
hours
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Ability to collect, organize and present
investigative materials apropriately to
support enforcement action
Knowledge of criminal investigative
skills and techniques (limited to most
senior EPA field personnel)
Classroom (EPA
lecture)
Classroom (Glynco,
GA)
Training for Levels I and II
Basic Skills
Knowledge of sampling techniques and
field testing and chain of custody
procedures
Understanding of investivative tech-
niques, inspection protocols, and inter*
action with regulated parties and the
public
Training/Methodology
Classroom (EPA lec-
ture) , OJT-40 hours
OJT-40 hours, Class-
room EPA lecture)
Training for Level II
Knowledge of Mobile Source technology
and emissions effects
Self-study, classroom
(Colorado State Univ.
and/or Ur.iv. of MI
course)
Training for Level III
Knowledge of refinery and importer
records and audit techniques for
lead phase-down investigation and
case development.
OJT-120 hours, self-
study (contractor
prepared manual)
B. TRAINING MA1]
The following materials are part of the Air-Mobile Source
Inspector Training Program.
1. Self-Study Materials
o Documents and publications on EPA mission, major clean
air issues, the federal motor vehicle emission control
program, and motor vehicle emission control technology
and emissions effects.
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3
o Applicable regulatory and statutory provisions.
o Textbook from University of Michigan's course "Combustion
Engine Emissions."
o Emission Controls Handbook from Colorado State University
training.
o General outline and flow chart for Level III audits.
Classroom Training
o University of Michigan 40 hour course entitled "Combustion
Engine Emissions." Deals with the theory of motor
vehicle emissions and the related control technology.
Presented once a year in Ann Arbor, Michigan and on
occasion presented to EPA employees in Washington, D.C.
o Criminal investigators training offered at the Federal Law
Enforcement Training Center in Glynco, Georgia.
o Colorado State University course entitled "Tampering
Detection Course." This is a 24 hour training session
presented by CSU staff and covering basic emission control
technology, identification of vehicle tampering, and
associated inspection techniques.
o EPA lectures on inspection protocols, public interaction,
evidence gathering, and presentation of investigation
results; and on basic orientation for non-EPA inspectors.
o Training sessions offered when available by auto
manufacturers regarding new technology.
-------
APPENDIX D-3
SUMMARY OF CERCLA INSPECTOR TRAINING
[TO BE DEVELOPED)
The Program-Specific Minimum Curriculum for On-Scene
Coordinators (OSCs) and Remedial Project Managers (RPMs) who lead
compliance inspections/field investigations under CERCLA is
currently under development. When completed the program-specific
materials will cover the subject matter in the Basic Inspector
Curriculum as veil as CERCLA-specific requirements.
As noted undor Section 5.a. of EPA Order 3500,1, OSWER will
provide additional program guidance to identify those oscs and
RPMs within the CERCLA program who are performing work covered by
this Order. For additional information contact: Division
Director, CERCIA Enforcement Division, Office of Waste Programs
Enforcement, office of Solid Waste and Emergency Response, 401 M
Street, S.W., (WH-527), Washington, DC 20460, FTS 8-382-4810;
E-Mail EPA 5240.
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APPENDIX D-4
SUMMARY OF NPDES
INSPECTOR TRAINING PROGRAM DESCRIPTION
A. SUMMARY
The NPDES Training Program establishes a core program, of
coursework, self instruction and on-the-job training (OJT) for
those individuals who carry out NPDES compliance/enforcement
activities for EPA. This summry describes a sequence for new
inspectors, and for expansion of skills later on. After
completion of Basic Training and Introductory NPDES training,
self-instruction and OJT, the inspector should be able to conduct
the compliance evaluation inspection and the sampling inspection.
The goal is for each new inspector to complete this sequence
within six to nine months on the job. Job skills can then be
expanded through more study and instruction into areas such as
performance audit, pretreatment,and diagnostic inspections.
The figure below shows the plan in summary fashion. In
order to get a copy of the complete NPDES Training Program
Description, contact: Director, Enforcement Division, Office of
Water Enforcement and Permits, HQ (EN-338), USEPA, 401 M Street,
SW, Washington, D.C. 20460. FTS 8-475-8488.
NPDES Training Plan
Courses/Workshops
General Orientation
I Self Instruction /OJT
Program-Minimum
Basic Inspector Curriculum
NPDES Introductory Coursework
(Manuals available by 4/88)
CWA and Regulations
Violation Recognition
Sampling Techniques
Manuals for Introduction
to Compliance Inspections
Flow Measurement Manual
OJT* 2 inspections each
for compliance evaluation
and compliance sampling
inspections
Skills Expansion
Pretreatment Inspection
Workshop
Diagnostic Inspection
Workshop
Pretreatment Guidance
Pretreatment Compliance
Inspection and Audit Manual
Inspector's Guide for Evalu-
ating Municipal Wastewater
Treatment Plants
-------
Toxics Sampling OJT-Biomonitoring, toxics
sampling and pretreatment
inspections (to be developed)
(To be developed)
Specialized Skills
Offshore Drilling Rig Inspections
(to be developed)
Criminal Investigations (FLETC, Glynco, GA)
B. TRAINING MATERIALS AND THEIR SOURCES
The following materials for the new inspector should be
available from the inspector's first-line supervisor or the
addresses footnoted below.
o general Orientation Package
- Organization chart
- Clean Water Act and regulations
- KPDES Inspection Strategies and Guidance such as the Clean
Water Act Compliance/Enforcement Compendium
- Sample NPDES inspection reports
- Description of HQ/Regional/State relationships
- NPDES Compliance Inspection Manual
o Introduction to KPDES Inspections fAvailable 4/88)
- NPDES Compliance Monitoring Inspector Training Modules 1
-- overview (draft)
Legal Issues (draft)
Sampling (draft)
Laboratory Analysis (under development)
Biomonitoring (under development)
Order «
- Field Manuals for Self Instruction and OJT NTIS IRC2
NPDES Compliance Inspection Manual PB85115897 068U
NPDES Flow Measurement Manual PB82131178/AS 050U
o Skills Expansion Coursework
- Pretreatment Inspections1
Pretreatment Compliance Monitoring and Enforcement
Guidance (July 1986)
Pretreatment Compliance Inspection and Audit
Manual for Approval Authorities (July 1986)
- Diagnostic Inspections IRC2
Inspectors Guide for Evaluation of Municipal 021U
Wastewater Treatment Plants, EPA/430/9-79-010
(April 1979)
-------
C. MAILING ADDRESSES!
1 Office of Water Enforcement and Permits, Enforcement Division
(EN-338) USEPA, 401 M Street, SW., Washington, D.C. 20460
2 U.S. Department of Commerce Instructional Resources
National Technical Information Center (IRC)
Service (NTIS) Ohio State University
5285 Port Royal Road 1200 Chambers Road, Room 310
Springfield, VA 22161 Columbus, OH 43212
(703) 487-4650 (614) 292-6717
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APPENDIX D-5
SUMMARY OP TOXIC SUBSTANCES/PESTICIDES PROGRAM TRAINING
A. SUMMARY
This training plan describes the required core and specialized
training for TSCA/FIFRA inspectors. It describes both the basic
requirements for new (i.e., either new to the inspection function
or new to OPTS) inspectors and specialized courses which are
required only for personnel who will be conducting inspections in
particular program areas (e.g., GLP inspections, asbestos
inspections, etc.). Both designated new and experienced
inspectors will take the specialized training.
After completing the TSCA/FIFRA overview and basic TSCA
inspection procedures (both within the first two months on the
job) and the OECM Basic Curriculum (within the first six months),
OPTS inspectors will be ready for a series of OJT and program
sub-speciality training and activities.
In order to get a copy of the complete description of the
TSCA/FIFRA training program, please contact Mike Wood, Chief,
Compliance Branch, Office of Compliance Monitoring, USEPA, 401
M Street, SW, (EN-342), Washington, D.C. 20460, Rm E-715,
FTS 8-382-7835.
The schematic below shows the plan in summmary fashion.
TSCA/FIFRA INSPECTOR TRAINING
I. Program-Min imum
Training
1. TSCA/FIFRA intro/
orientation
(required unless
has equivalent
training)
2. Basic TSCA/FIFRA
Inspection
Procedures
(required)
3. OECM Basic
Curriculum
(required or
equivalent)
Method of Instruction
mostly self-study
mostly self-study
(some lecture)
coursework or
equivalent
Timing
80 hrs. within
first two months
on job
10 hrs. within
first two months
on job
up to 80 hrs.
(depending on
individual) within
first six months on
job
-------
Training
4. OJT Office
Preparation
to prepare
inspector for
field work
(required)
5. OJT Field
Experience
(recommended)
Training
6. OJT Inspections
(recommended)
7. TSCA/FIFRA
Case Preparation
Procedures
(recommended)
Method of Instruction
supervised OJT
Timing
20-60 hrs.
(depending on
individual) prior
to first field
inspection
3-6 supervised
OJT inspections
as a junior inspector
8-32 hrs. per
inspection within
first six months
on job
Method of Instruction Timing
solo inspection at
5-10 facilities
(Supervisor evaluates
inspection report)
classroom (lecture),
case studies
8-45 hrs. per
inspection after
completion of
1,2,3
estimated 24 hrs.
(taken as offered)
II. Specialized Training
Section-specific Seminars, Workshops,
detailed training and individually-
(reguired for designed training
designated sessions
inspectors)
TSCA
2-32 hrs. depen-
ding on the sec-
tion-specific
training (after
completion of 1
and 2)
Testing (s4); PKH (s5); PCB's (s6); Reporting (s8);
Imports/Exports (S12/13); Asbestos; SARA Title III (s313)
FIFRA
GLP; Cancellation/Suspension; Recalls/SSURO; Establishment
Inspections; Use Investigations; Exp. Use Permit; Imports;
Reporting [including s6(a)(2)]
B. TRAINING MATERIAL? AND THEIR SOURCES
The following materials should be available from the
inspector's first line supervisor:
-------
Prooram-Minumum
1. FSCS/FIFRA statutues and 40 CFR regulations; TSCA
Manual; FIFRA Inspection Manual; TSCA and FIFRA
Policy Compendiums
2. FIFRA and TSCA Inspections Manuals
3. Five OECM Basic Curriculum Modules
4. Computerized Data Bases; Regional Inspection Report;
Company Files
5. TSCA and FIFRA Inspection Manuals; Inspection Forms;
Site Safety and Sampling Plans (as necessary)
-------
APPENDIX D-6
PUBLIC WATER SYSTEM SUPERVISION
PROGRAM SPECIFIC INSPECTOR TRAINING
I. INTRODUCTION AND PURPOSE
The purpose of the PWSS training program is to take a
structured approach to the training of PWSS inspectors (those who
conduct or oversee compliance and enforcement activities in the
field) in order to strengthen the effectiveness of their
activities. While the program is specifically applicable to EPA
inspectors, it may be of interest to States who conduct the vast
majority of PWSS inspections. As a national program it
establishes a core of essential training which may be
supplemented as needed.
II. DESCRIPTION OF TRAINING COMPONENTS
The purpose of a training plan is to ensure opportunity of
every inspector to acquire and refine the skills and knowledge
needed to perform effectively. To that end, a set of experiences
should be made available, over time, including; formal course
work, self instruction and on the job training.
All inspectors for the PWSS program should be able to
conduct PWSS inspections including sanitary surveys and
enforcement case development inspections. In addition, EPA
personnel should be able to provide assistance to State
inspectors.
Basic Inspector Training and Sanitary Survey training, self-
instruction and on-the-job training are currently planned or
available for EPA inspectors. In addition, supplemental training
will also need to be developed as new requirements under the SDWA
come into effect.
III. SUGGESTED SEQUENCING /
The sequence of training should be decided by the
supervisor in conjunction with the inspector after considering
the inspector's level of experience and the unique needs of the
Region. The sequencing will also be determined by the
availability of courses and the scheduling of inspections. In
general, the suggested sequence for all inspectors is as follows:
Orientation, Basic Inspector Curriculum, Sanitary Survey Course,
self study, computer based training and on-the-job experience.
For experienced inspector, training needs should be decided in
consultation with the first-line supervisor using Supervisor's
Guide to determine if exceptions for training are appropriate.
However, it may be desirable to attend the Basic Inspector
Training Curriculum and/or Sanitary Survey Course so that EPA
inspectors have a common understanding with States. Basic skills
-------
and knowledge which all inspectors will be expected to acquire,
and the associated training experiences, are detailed as
Attachment A.
IV. TRAINING MATERIALS AND THEIR SOURCES
The following kinds of materials for new inspectors should
be available from the inspector's first-line supervisor.
o General Orientation
- Organization chart
- SDWA and regulations
- FWSS Compliance Strategy
- Description of HQ/Regional/State relationships
- Applicable guidance and policy documents
o Sanitary Survey Course
- Sanitary Survey Manual (small systems)
- Training modules (large systems - to be developed)
o Program Management Training
- (to be developed)
o Skills Expansion
- (to be developed)
-------
ATTACHMENT A
UIC Program-Specific Minimus and Specialized Training
SKILLS AND ASSOCIATED TRAINING
Basic SkilI/Knowledge Needed Associated Training Experience
Knowledge of EPA enforce-
ment philosophy and stra-
tegies
o Basic Inspector Training
Ability to complete enforce- o Basic Inspector Training
ment fact gathering, with
understanding of ethics,
right of entry and inspec-
tor conduct
o Understanding of health and
safety requirements
o Health and Safety Training
o Understanding of the mission o Orientation (self study)
authority of the UIC program,
and enforcement strategies
o Knowledge of basic UIC tech-
nical processes, causes of
noncompliance, ways to
improve operations in large
and small systems
o A working knowledge of vio-
lation recognition, sampling
procedures and laboratory
analysis
o A working knowledge off
applicable State programs
and procedures and ability
to provide constructive over-
sight
o Knowledge of field con-
ditions and procedures
o Inspection Manual (self-
study) Inspection Manual
Training (TBD) Seminars1
o OJT
Special courses1
o Program Management Training
(OJT/self study)1
o Formal Field Training(TBD)1
^specialized training as needed
-------
APPENDIX D-7
SUMMARY OF RCRA INSPECTOR TRAINING
A. SUMMARY
The RCRA Training Program establishes the minimum
knowledge, skills and abilities necessary for those individuals
S- carry °ut lead RCRA inspections, while providing flexibility
in training delivery methods. The program states that courses,
supervised independent study and on-the-job training should all
be used depending on availability, resources and the needs of
the inspector. This summary describes the program for
inspectors.
The training curriculum outlined below must be completed
before the inspector conducts lead inspections (some exceptions
may be allowed based on the supervisor's judgment and only if
the actions do not jeopardize pcr-ible enforcement actions or
human safety.) After the training, the supervisor will make a
determination as to whether the inspect is sufficiently
prepared to perform as a lead inspector. !ontact: RCRA
Enforcement Division Director, Office of aste Programs
Enforcement, Headquarters (WH-527), USEPA, 401 M Street, SW,
Washington D.C. 20460; FTS 382-4808.
The figure below shows the plan in summary.
RCRA Training Plan
; I
l l
Coursework Supervised Independent 3elf-
Studv/OJT
(delivery method opt. -»naV
1. General Orientation
2. Health and Safety
3. RCRA Regulatory Framework
(courses available)
4. RCRA Inspections RCRA Inspections OJT:
(courses available) . minimum of 30 hours and
4 facility types
B. TRAINING MATERIALS
The following materials for the inspector are suggested:
1. General Orientation
- RCRA Orientation Manual
- Understanding the Small Quantity Generators (SQG)
Hazardous Waste Rules
-------
- The Resource Conservation and Recovery Act
- Videos (e.g., CSRCLA's RCRA Overview)
- State developed materials covering related topics
2. Health and Safety
- materials to be developed
3. RCRA Regulatory Framework
- 40 CFR hazardous waste regulations
- RCRA statute
- HSWA statute
4. RCRA Inspections
- Inspection Manuals:
RCRA
State Oversight
Compliance Monitoring Evaluation
Land Disposal Restrictions
Technical Case Development
Hazardous Waste Tanks
Operations and Maintenance
Lab Audit
- Effluent Guidelines
- Equipment Manufacturer Operating Manuals
- 40 CFR Hazardous Waste Regulations
- SW-846
- Groundwater Monitoring Technical Enforcement Guidance
Document
- Groundwater Monitoring Compliance Order Guide
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APPENDIX D-8
SUMMARY
UNDERGROUND INJECTION CONTROL
PROGRAM SPECIFIC INSPECTOR TRAINING
I. INTRODUCTION AND PURPOSE
The purpose of this UIC training program is to take a
structured approach to the training of UIC inspectors (those who
conduct or oversee compliance and enforcement activities in the
field) to strengthen the effectiveness of their activities.
While the program is specifically applicable to EPA inspectors,
it nay be of interest to States who conduct inspection in primacy
programs. As a national program it establishes a core of
essential training which may be supplemented as needed.
\
II. DESCRIPTION OF RECOMMENDED TRAINING COMPONENTS
The purpose of a training plan is to ensure opportunity for
every inspector to acquire and refine the skills and knowledge
needed to perform effectively. To that end, a set of experiences
should be made available over time including formal course work,
self instruction and on the job training.
Inspectors for the UIC program should be able to conduct
required field and monitoring activities and enforcement related
activities. EPA personnel, in addition, should be able to
provide oversight and assistance to State and contractor
inspectors.
Basic Inspector Training and UIC technical training, self-
instruction and on-the-job training are currently planned or
available for EPA inspectors. In addition, supplemental training
will also be needed to be developed to address new program areas
and enforcement -needs.
III. SUGGESTED SEQUENCING
The sequence of training should be decided by the supervisor
in conjunction with the inspector, and after considering the
inspector's level of experience and the unique needs of the
.Region. The sequencing should take advantage of the availability
of courses and the scheduling of inspections. In general, the
suggested sequence for all inspectors is as follows:
Orientation, Basic Inspector Curriculum, self study, technical
courses and on-the-job experience and training. For experienced
inspectors, training needs should be decided in consultation with
the first-line supervisor using the Supervisor's Guide to
determine if exceptions for training are appropriate. However,
it may be desirable to attend the Basic Inspector Tr-» \ning
Curriculum and/or structured field training so that EPA
inspectors have a common understanding with States and remain
-------
and knowledge which all inspectors will be expected to acquire,
and the associated training experiences, are detailed as
Attachment A.
IV. TRAINING MATERIALS AND THEIR SOURCES
The following kinds of materials for new inspectors should
be available from the inspector's first-line supervisor.
o General Orientation
- Organization, chart
- SDWA and regulations
- PWSS Compliance Strategy
- Description of HQ/Regional/State relationships
- Applicable guidance and policy documents
o Sanitary Survey Course
Sanitary Survey Manual (small systems)
- Training modules (large systems - to be developed)
o Program Management Training
- (to be developed)
o Skills Expansion
- (to be developed)
-------
ATTACHMENT A
UIC Program-Specific Minimum and Specialized Training
SKILLS AND ASSOCIATED TRAINING
Basic Skill/Knowledge Needed Associated Training Experience
Knowledge of EPA enforce-
ment philosophy and stra-
tegies
o Basic Inspector Training
Ability to complete enforce- o Basic Inspector Training
ment fact, gathering, with
understanding of ethics,
right of entry and inspec-
tor conduct
Understanding of health and
safety requirements
Understanding of the mission
authority of the UIC program,
and enforcement strategies
Knowledge of basic UIC tech-
nical processes, causes of
noncompliance, ways to
improve operations in large
and small systems
A working knowledge of vio-
lation recognition, sampling
procedures and laboratory
analysis
A working knowledge off
applicable State programs
and procedures and ability
to provide constructive over-
sight
Knowledge of field con-
ditions and procedures
o Health and Safety Training
o Orientation (self study)
Inspection Manual (self-
study) Inspection Manual
Training (.TBD) Seminars1
OJT
Special courses1
Program Management Training
(OJT/self study)1
o Formal Field Training(TBD)1
^-specialized training as needed
-------
APPENDIX D-9
SUMMARY OP WETLANDS PROTECTION INSPECTOR TRAINING
[TO BE DEVELOPED]
The Office of Wetlands Protection is developing a Program-
Specific Minimum Curriculum for inspections/investigations under
the wetlands protection program of the Clean Water Act, Section
404. OWP anticipates that the training materials and course will
be available during FY 1989.
For additional information, contact: Hazel Groman,
Enforcement Coordinator, Office of Wetlands Protection,
Regulatory Activities Division, 401 M Street, S.W., (A-104F),
Washington, D.C. 20460, FTS 8-475-8798.
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APPENDIX E
SUMMARY OF RECOMMENDED
MULTI-MEDIA (MULTI-PROGRAM) TRAINING .
Multi-Media (Multi-Program) Training is designed to foster
knowledge and skill in two or more compliance programs.
This training nay occur for different compliance programs
under one environmental statute or under different statutes.
Preparation of this kind may be desirable, depending on the
resources and needs of each Regional Office. Having inspectors
with cross program training and experience would enable more
efficient use of travel time and money by allowing coordination
of inspections in a given geographical area. Also cross
training builds a flexible work force which can respond to
changing needs, and changing resource levels. Decisions on the
appropriate mix and level of cross program training are at
the discretion of Regional Management.
A. Multi-Media fMulti-Program Inspection Screening Course
(Level 11
This one-day course is designed to prepare compliance
inspectors/field investigators to recognize and report on
obvious, key indicators of possible non-compliance in all
environmental program areas relevant to a particular facility
or site. The objective is to broaden the awareness of cross-
program and cross-media concerns, thus enabling the inspector/
field investigator to be a more effective representative of
EPA as a whole. (This training would go beyond the overview
of all enforcement programs in the Basic Curriculum.) Identi-
fication of non-compliance problems could result subsequently
in a full inspection(s) for one or more environmental programs at
the facility. The course would be most useful to employees who
already have experience with compliance inspections/field
investigations, and/or who spend a substantial portion of
their time e.g., 20% or more performing compliance inspections/
field investigations. OECM will work with the Programs and
Regions to develop this training course in FY 1989.
B. Multi-Media fMulti-Program) Inspection Training (Level 2)
This level of training means completing the required
Program-Specific Minimum Curricula (and specialized training,
if appropriate) in two or more Compliance Programs so that
the individual compliance inspector/field investigator is
fully prepared to lead inspections in two or more programs
at a facility(ies). Regions are encouraged to support this
level of training where the relationship between the requirements
of two or more programs or the location of facilities makes
it cost-effective to do so.
-------
C. Multi-Media. fMulti-Proarann Team Inspection Training fLevel 3^
Depending or Regional Office needs and resources, a multi-
media (program) inspection which addresses all' relevant
program requirements operative for a single facility may be
desirable. To support the development of compliance inspectors/
field investigators to lead such multi-media inspections
carried out by a team, the following training is recommended.
In addition to completion of the 1) Basic Curriculum, 2) Program
Specific Curricula in two or more Compliance Programs and
3) significant experience in leading inspections in more than
one program, specialized training in directing the activities
of a team inspecting a facility is appropriate. Such training
would develop organizational and supervisory skills and an
ability to-grasp and convey cross-program issues and
interrelationships. The National Enforcement Investigations
Center (NEIC) has provided multi-media training. Any request for
such training should be sent to Robert Harp, NEIC, Building 53,
Box 25227, Denver Federal Center, Denver, CO, 80225;
[FTS 8-776-5100; Commercial 303-236-5100.]
Each Region is encouraged to develop and train at least
one team leader for multi-media, team inspections/investigations,
and to decide where such inspections would have significant
benefits for deterring non-compliance.
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APPENDIX P
SUPPLEMENTAL TRAINING
1. Administrative Hearings/Trials: EPA Institute*
One-day course designed for technical and legal personnel
involved in administrative case preparation and presentation.
Covers types of administrative hearings, steps in the hearing
process, prehearing conferences, preparation of evidence and
witnesses, appeals.
2. Expert Witnesst EPA Institute*
One-day course designed for EPA personnel who need an under-
standing of the legal process and/or who may serve as an
expert witness. Covers the legal system, anatomy of a lawsuit,
what to expect of depositions and of direct and cross
examinations at a trial.
3. Negotiation Skills; EPA Institute*
Two-day course designed for enforcement personnel. Covers basic
negotiation concepts, planning for negotiations, tactics for
expediting negotiations, EPA position on issues commonly
found in settlement negotiations.
4. Criminal Investigations; Federal Law Enforcement Training
Center (FLETC)
The Federal Law Enforcement Training Center (FLETC) in Brunswick,
Georgia, offers criminal investigation training to EPA technical
personnel on an infrequent basis. In late FY '88 or early
FY '89, FLETC will present eight days of classroom instruct-
ion on recognizing and responding to criminal violations of
environmental laws. The course will cover subjects'such as
developing sources of information, interviewing techniques,
search and seizure issues, and collection and protection of
evidence. Also to be covered are functions and services of
the Office of Criminal Investigations and laboratory and other
services of EPA's National Enforcement Investigation .Center
(NEIC) and the Environmental Photographic Interpretation
Center. Classroom instruction will be augmented by crime
scene and courtroom practical exercises. Class size is
limited to 24. For additional information, contact Phillip
Andrew in Brunswick, Georgia, at FTS 8-230-2726.
* EPA Institute
For more information about individual courses (faculty, dates,
locations) or about the Institute, contact: Director, EPA
Institute, Office of Administration, 401 M Street, S.W., (PM-
224), Washington, D.C. 20460, FTS 8-382-2594, E-mail EPA3880).
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5. Automated Information Systems for Compliance Inspectors/
Field Investiaa^oysi National Enforcement Investigations
Center (NEIC)
NEIC will develop a one-day course for inspectors and
investigators to provide familiarity with the full range of
ADP support available to EPA and State personnel. The course
will cover EPA's Major National Program Compliance and
Enforcement systems as veil as supplemental sources from both the
private and public sector. For more information contact Robert
Harp, NEIC, Box 25227, Denver Federal Center, Denver CO.
[FTS 8-776-5100; Commercial 303-236-5100]
-------
APPENDIX G
ACCOUNTABILITY FOR INSPECTOR TRAINING
Ensuring that training occurs requires an effective
system of accountability within Headquarters and the Regions.
Without this, training for compliance inspectors/field
investigators may continue in a haphazard rather than a
consistent, continuing way. This appendix contains a more
detailed list of the functions that need to be performed by
different organizations to effectively implement this program.
A. Headquarters* Responsibilities
1. AA for OECM. The AA for Enforcement and Compliance
Monitoring (OECM) or his/her designee is responsible for the
following:
a. Updating EPA Order 3500.1, overseeing and evaluating
implementation of the overall program requirements
and reporting to the Administrator and Assistant
Administrators;
b. Coordinating a major evaluation of program implement-
t ion in three years with the assistance of the Office
of Policy, Planning and Evaluation (OPPE);
c. Developing, updating and disseminating student manuals
and instructors' guides for the Basic Curriculum to
Regions and Headquarters;
d. Coordinating selection of instructors for the Basic
Curriculum, and maintaining a national list of
instructors from Regions and Headquarters;
e. Developing guides for first-line supervisors to use
in evaluating individual training needs and requesting
exceptions when applying the requirements of EPA Order
3500.1 with respect to the Basic Curriculum;
f. Organizing a board of Senior Agency Managers and
inspectors/investigators from Headquarters and Regions,
to advise him/her in carrying out these responsi-
bilities;
g. Working with RAs and AAs to jointly recognize excellence
in compliance monitoring inspections/investigations; and
h. Assigning functions needed within OECM for implemen-
tation of these responsibilities and incorporating then
into the performance standards of responsible
individuals.
2. AA for OARM. The AA for Administration and Resources
Management or his/her designee is responsible for the
following:
a. Updating and providing sufficient materials for
occupational health and safety training, or approving
non-EPA courses to meet the requirements of EPA Orders
-------
1440.2 and 1440.3, and reviewing program-specific
health and safety training;
b. Working with OECM and the EPA Institute to coordinate
selection of instructors for Inspector Health and
Safety Curriculua and aaintaining a national list;
(OHSS)
c. Training EPA instructors in effective teaching
methods for the Basic Curriculua; (EPA Institute)
d. Working with Regions and Prograas to evaluate
instructors' performance and provide useful
feedback; (EPA Institute)
e. Coordinating and disseminating a tiaely schedule
of classes for the Health and Safety, Basic and
Program-Specific Curricula, in consultation with
OECM, Prograa offices and the Regions using the
E-Train Information Systea; (PHD) and
f. Assigning functions needed within OARM for
implementation and incorporating thea into the
performance standards of responsible individuals.
3. AAs for Media Programs; Each Assistant Adainistrator or
his/her designee is responsible for the following:
a. Developing, updating and disseminating materials and
schedules for classes under the Program-Specific
Curriculum(a), including advanced or specialized
training, in consultation with Regions and States;
b. Conducting surveys of Regions' and States' needs, and
periodic reviews of the entire Program-Specific
Minimum and Specialized Curricula;
c. Ensuring in future contracts and assistance agreements
awarded under the Senior Environmental Employment
Program, involving compliance inspections that
training is required by means of statements of work
or other appropriate vehicles;
d. Developing guides for first-line supervisors
to use in evaluating individual training needs and
in requesting exceptions when applying the require-
ments of this Order with respect to the Program-
Specific Minimum Curricula;
. Assisting Regions by providing training delivery
contracts, or grants to university training centers
or other non-profit organizations for training delivery
where useful and effective;
f. For those programs with Headquarters-based inspectors,
or for OECM and NEIC, identifying who is subject to
EPA Order 3500.1 approving requests for exceptions for
these personnel, planning for delivery of the Basic
Curriculum and submitting a plan for this to OECM by
pctober 30. 19B8. and incorporating training
requirements into position descriptions and performance
standards;
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g. Establishing standing work groups including Regions,
and States where appropriate, to help carry out
these responsibilities and to improve the quality of
the compliance monitoring function; and
h. Assigning functions needed within the Media Program
Offices to implement this Order and incorporating
them into appropriate performance standards, such as
the general management standard.
B. Regions* Responsibilities*
1. RA. Each Regional Administrator is responsible for the
following:
a. Establishing an internal system, assigning functions
for implementation of the Basic Curriculum, and
submitting a plan that explains this operation to
OECM by October 30. 1988;
b. Determining who is subject to this Order and
maintaining records of those individuals and their
training accomplishments and/or exceptions;
c. Designating the DRA or a cross-Regional panel to
review and approve any exceptions to the requirements
of this policy;
d. Supporting in-house instruction for the Basic
Curriculum by working with OECM to identify Regional
personnel to serve as classroom instructors and keeping
a current roster of trained instructors;
e. Scheduling the Basic Curriculum annually and
communicating it to OECM, OARM and other Regions;
f. Incorporating training requirements into position
descriptions and performance standards;
g. Ensuring in future contracts involving compliance
inspections that training is required by means of
statements of work or other appropriate vehicles;
h. Maintaining a sufficient supply of training materials
for Basic and Program-Specific Minimum Curricula
in the Region;
i. Ensuring each Regional program identifies States'
inspector training needs annually through the
State/EPA Enforcement Agreements process;
j. Assisting States in identifying ways to meet their
training needs and coordinating training opportunities;
and
k. Assigning functions needed within the Region to
implement EPA Order 3500.1 and incorporating them into
appropriate performance standards.
*These responsibilities apply to any AA having conoliance
inspectors/investigators based in Headquarters such as the
AA for Air and Radiation for Mobile Sources Enforcement.
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2. Line Supervisors. Line supervisors, in Program or
Environmental Services Divisions, are responsible for the
following:
a. Ensuring quality compliance inspections/field invest-
igations using performance standards, periodic
appraisal, appropriate assignments to ensure
development, and recognition of personnel engaged in
the compliance monitoring function;
b. Working with each assigned compliance inspector to
identify training needs and to incorporate these
into an Individual Development Plan (IDP);
c. Preparing written requests for exceptions to EPA
Order 3500.1 and securing these in accordance with .
procedures established in the Region or in
Headquarters;
d. Providing self-instruction materials and structured
on-the-job training experiences, and assuring that
assignments meet the requirements of this training
program;
e. Designating OJT instructors and preparing them for
this assignment;
f. Reviewing progress and maintaining records of indivi-
duals subject to EPA Order 3500.1 including their
accomplishments and/or exceptions;
g. Incorporating training requirements into position
descriptions and performance standards of responsible
individuals;
h. Completing required training; and
i. Evaluating the effectiveness of training materials and
methods.
3. Compliance Inspectors/Field Investigators. Compliance
Inspectors/Field Investigators are responsible for the following;
a. Advising their supervisor about the history, and
extent of relevant training and experience, and
assisting in the preparation of an Individual
Development Plan (IDP) to meet the requirements of
EPA Order 3500.1;
b. Assisting in locating training courses to meet the
objectives of EPA Order 3500.1;
c. Evaluating the effectiveness of training materials
and methods;
d. If selected as an OJT instructor, planning and
preparing for this assignment; and
e. Applying and maintaining the knowledge, skills and
techniques acquired through training to ensure that
inspections/investigations are accomplished in a
technically and legally sound manner.
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