MTR 94W0000082V1
Assessment of the Scientific and Technical
Laboratories and Facilities of the
U.S. Environmental Protection Agency
May 1994
MITRE
McLean, Virginia
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Assessment of the Scientific and Technical
Laboratories and Facilities of the
U.S. Environmental Protection Agency
Linda J. Duncan
Willard E. Fraize
Dabney G. Hart
John L. Menke
David L. Morrison
Brian H. Price
Brant E. Smith
Timothy K. Underwood
Kerry R. Zimmerman
MTR94W0000082V1
May 1994
CLIENT:
U.S. Environmental Protection Agency
CONTRACT NO.:
68D40003
Approved for public release, distribution unlimited
MITRE
Center for Environment, Resources and Space
7525 Colshire Drive
McLean, Virginia 22102-3481
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ACKNOWLEDGEMENTS
The MITRE staff who contributed to this study of EPA's laboratories and to the
preparation of this report wish to acknowledge, with gratitude, the dozens of truly
dedicated individuals who took time from their other important activities relating to
environmental protection to provide data and information, as well as their insights into the
organization and operation of the Agency's laboratories. Without their help, patience, and
good humor, this study could not have been completed within the timeframe set by
Congress.
The principal authors would like to thank the following members of MITRE's
technical staff that assisted in the laboratory interviews, data compilation, and peer
review: George Bizzigotti, John DeSesso, Sam Hopper, Steve Hsia, Daisy Ligon, Dick
Manley, Jim Morgan, Dave Roberts, Marcy Saynuk, Bob Sextro, Fred Steinberg, Greg
Vogel, Pam Walker, Marc Weiner, and Tom Wolfmger. Sherrill Edwards was responsible
for the final compilation and editing of the document.
The authors would also like to recognize the following members of the support staff
for their efforts in putting together a document of this magnitude: Harry Cummins, Ellen
Friedman, Nancy Hoss, Pauline Kapoor, Judith Pals, Marlene Threlfall, Sue Walters,
Paula Wright, and Rose Zepeda.
111
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TABLE OF CONTENTS
SECTION PAGE
1 Introduction 1-1
1.1 Background of the Study 1-1
1.2 EPA Organization 1-3
1.3 Organization of the Document 1-6
2 Objectives and Methodology 2-1
2.1 Objectives 2-1
2.2 Methodology 2-2
2.2.1 Information Acquisition 2-2
2.2.2 Information Synthesis 2-3
2.2.3 Options Development and Analysis 2-4
3 Recent Studies Relevant to EPA Research or Laboratory Functions 3-1
3.1 Past Studies of EPA Laboratories 3-1
3.1.1 The Expert Panel Report 3-3
3.1.2 The National Academy of Public Administration 3-4
Report
3.1.3 The Carnegie Report 3-6
3.1.4 The Streamlining Report 3-6
3.1.5 The National Institute for the Environment Report 3-10
3.1.6 The National Research Council Report 3-10
3.2 Conclusions Drawn by Previous Studies 3-10
3.3 Summary of Previous Studies 3-15
4 Current Laboratory Missions and Operations 4-1
4.1 Scientific and Technological Missions 4-1
4.1.1 EPA's Mission 4-1
4.1.2 Scientific and Technological Functions 4-6
4.2 EPA's Laboratory Organization 4-13
4.2.1 Current Organization 4-13
4.2.2 Missions of the Laboratories 4-19
4.2.3 Laboratory and Mission Alignment 4-29
4.3 Activity Planning 4-29
4.3.1 ORD and Issue-Based Planning 4-29
4.3.2 Program Office Laboratories and ESOs 4-34
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SECTION PAGE
4.4 Finances ~ .
4-42
4.5 Facilities and Equipment
4.6 Human Resources
4.6.1 Intramural Resources
4.6.2 Extramural Resources 4~63
5 Issues and Customers
5.1 Customers 5-2
5.2 Comments and Issues 5-7
5.2.1 Mission Focus 5-7
5.2.2 Expectations 5-8
5.2.3 Locus of Control 5-10
5.2.4 Administrative Impediments 5-11
5.3 Summary of Issues 5-13
5.3.1 ORD Laboratory Summary Issues 5-14
5.3.2 Program Office Laboratory Summary Issues 5-14
5.3.3 ESO Summary Issues 5-15
5.4 State Laboratories 5-16
5.5 Private Sector Organizations 5-18
6 Management Improvements 6-1
6.1 Quality Assurance 6-1
6.2 Mission Clarification 6-1
6.3 Planning and Priority-Setting 6-2
6.4 Delegation of Authority 6-2
6.5 Impediments to Laboratory Productivity 6-3
6.6 Management Improvements in Response to Impediments 6-7
6.6.1 Ad Hoc Responses 6-7
6.6.2 Systematic Responses 6-9
7 Structure for Analysis of Options 7-1
7.1 Introduction 7-1
7.2 Option Description 7-1
7.2.1 Baseline 7-2
7.2.2 Customer Orientation 7-4
7.2.3 Streamlining 7-14
7.2.4 Carnegie Commission 7-17
7.2.5 Distinct Environmental Services Organization 7-23
7.2.6 Geographic Location 7-33
VI
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SECTION PAGE
7.3 Evaluation Criteria 7-34
7.3.1 Criteria for Effective Use of Agency Resources 7-35
7.3.2 Criteria for Efficient Use of Agency Resources 7-37
7.3.3 Criteria for Implementation 7-38
8 Evaluation of Options 8-1
8.1 Introduction 8-1
8.2 Methodology for Analysis 8-1
8.3 Analysis of Options 8-3
8.3.1 Customer Orientation 8-3
8.3.2 Streamlining 8-4
8.3.3 Carnegie Commission 8-6
8.3.4 Distinct Environmental Services Organization 8-7
8.3.5 Geographic Location 8-8
8.4 Analysis of Criteria 8-10
8.4.1 Criteria for Effective Use of Agency Resources 8-10
8.4.2 Criteria for Efficient Use of Agency Resources 8-11
8.4.3 Criteria for Implementation 8-13
8.5 Summary 8-13
9 Other Federal Models 9-1
9.1 U.S. Food and Drug Administration 9-1
9.1.1 Mission 9-1
9.1.2 Science Base 9-2
9.1.3 Scientific Organization 9-3
9.1.4 Program Management 9-5
9.1.5 Resources and Constraints 9-5
9.1.6 Strategies for the Future 9-9
9.2 The National Institutes of Health 9-10
9.2.1 Mission 9-10
9.2.2 Organization and Funding 9-12
9.2.3 Science Base 9-16
9.2.4 Administrative Issues 9-17
9.3 U.S. Nuclear Regulatory Commission 9-18
9.3.1 Introduction 9-18
9.3.2 Mission 9-18
9.3.3 Organization and Operations 9-19
9.4 Summary 9-20
Vll
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SECTION PAGE
10 Alternative Accountability Models 10-1
10.1 Federal Contract Research Centers 10-1
10.2 Contracting at Government-Owned, Contractor-Operated 10-4
Organizations
10.3 Implications for EPA Laboratories 10-5
10.3.1 Establishment of an FFRDC 10-5
10.3.2 Impacts on Issues 10-6
10.4 Conclusions 10-8
11 Findings 11-1
12 Bibliography 12-1
Glossary of Acronyms GL-1
Appendix A Laboratory Descriptions A-l
Appendix B Schedule Highlights B-l
Appendix C Executive Interview Summaries C-l
Vlll
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LIST OF TABLES
TABLE PAGE
3-1 Past Studies Affecting EPA Laboratory Activities and 3-2
Organization
3-2a & 3-2b Safeguarding the Future: Credible Science, Credible Decisions, 3-5
Report of Expert Panel on the Role of Science at EPA, March 1992
3-3a & 3-3b ORD: Leadership and Staff for a New Agenda, 3-7
The NAPA Report, July 1990
3-4 Environmental Research and Development, Carnegie 3-8
Commission, December 1992
3-5a & 3-5b Plan for Reinventing and Streamlining ORD, February 1994 3-9
3-6a & 3-6b Proposal for the National Institute for the Environment, 3-11
August 1993
3-7a & 3-7b Research to Protect, Restore, and Manage the Environment, 3-12
National Research Council, 1993
4-1 EPA Mission Elements Linked to Scientific and 4-9
Technological Functions
4-2 Function Distribution of EPA Laboratories, 4-22
ORD Laboratories
4-3 Function Distribution of EPA Laboratories, 4-24
Program Office Laboratories
4-4 Function Distribution of EPA Laboratories, 4-26
Environmental Services Organizations
4-5 Distribution of Laboratory Functions by Environmental 4-30
Problem
4-6 FTE From 1994 Laboratory Implementation Plans 4-32
IX
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TABLE PAGE
4-7 EPA Appropriations 4-35
4-8 EPA FY93 Laboratory Financial Data Summary 4-36
4-9 FY93 OARM Expenditures On Behalf of Laboratories 4-40
(B&F, Rents, and Utilities)
4-10 EPA FY93 Laboratory Expenditures as a Percentage 4-41
of EPA FY93 Appropriations
4-11 Facilities and Equipment (F&E) Expenditures Summary 4-43
(Ordered By Total F&E Expenditures)
4-12 Laboratory Space Summary 4-46
4-13 Equipment Inventory Summary (Purchase Price >$50,000) 4-49
ORD Laboratories
4-14 Equipment Inventory Summary (Purchase Price >$50,000) 4-51
Program Office Laboratories
4-15 Equipment Inventory Summary (Purchase Price >$50,000) 4-52
Environmental Services Organizations
4-16 Percentage Distribution of Reported Work Activities, 4-64
ORD Headquarters Offices and Laboratories
4-17 Percentage Distribution of Reported Work Activities, 4-66
Program Office Laboratories
4-18 Percentage Distribution of Reported Work Activities, 4-67
Environmental Services Organizations
4-19 Number of Degrees (GS9 and Above), ORD Laboratories 4-68
4-20 Number of Degrees (GS9 and Above), Program 4-70
Office Laboratories
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TABLE PAGE
4-21 Number of Degrees (GS9 and Above), Environmental 4-71
Services Organizations
4-22 On-Site Intramural and Extramural Workforce Summary, 4-72
ORD Laboratories
4-23 On-Site Intramural and Extramural Workforce Summary, 4-73
Program Office Laboratories and Environmental Services
Organizations
5-1 Consolidated ORD Customer List 5-3
5-2 ESO Customer List 5-6
7-1 Distribution of FY93 Scientific and Technological Resources 7-4
8-1 Evaluation of Options 8-2
9-la FDA's FY93 Agency FTEs by Program and Strategic Area 9-7
9-lb FDA's FY93 Agency Dollars by Strategic Area 9-8
9-lc FDA's FY93 Agency Dollars by Program 9-8
9-2 National Support for Health Research and Development 9-14
9-3 1992 Distribution of NIH Health Research and Development 9-14
Funds by Performer
9-4 Distribution of 1992 NIH Obligations 9-15
9-5 U.S. Nuclear Regulatory Commission Research Funding 9-20
by Category
XI
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LIST OF FIGURES
FIGURE PAGE
4-1 Mission of EPA, Showing Derivative Operational 4-5
Components
4-2 Current Laboratory Structure 4-14
4-3 Number of FTE Staff (FY94), ORD Laboratories 4-15
4-4 Number of FTE Staff (FY94), Program Office Laboratories and 4-17
Environmental Services Organizations
4-5 FTE by Scientific and Technological Function by Laboratory Type 4-20
4-6 FTE by Scientific and Technological Function, ORD Laboratories 4-21
4-7 FTE by Scientific and Technological Function, Program 4-23
Office Laboratories
4-8 FTE by Scientific and Technological Function, Environmental 4-25
Services Organizations
4-9 FY93 EPA Laboratory Expenditures, ORD Laboratories 4-38
4-10 FY93 EPA Laboratory Expenditures, Program Office 4-39
Laboratories and Environmental Services Organizations
4-11 Average Annual Facilities and Equipment Expenditures 4-45
per Unit Work-Year (FY93)
4-12 Facility Space by Laboratory 4-54
4-13 Approximate Number of Facility Occupants (Based on 4-55
Workforce Data)
4-14 Total Facility Space By Location 4-56
Xll
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FIGURE PAGE
4-15 Approximate Total Facility Occupants By Location 4-57
4-16 FTE by Discipline (Degrees) for Program Office Laboratories and 4-58
Environmental Services Organizations for all Grades GS9 and Above
4-17 FTE by Discipline (Degrees) for ORD Laboratories for all 4-59
Grades GS9 and Above
4-18 Intramural Workforce Age Distribution, ORD Laboratories 4-60
4-19 Intramural Workforce Age Distribution, Program Office Laboratories 4-61
4-20 Intramural Workforce Age Distribution, Environmental Services 4-62
Organizations
4-21 Laboratory Workforce Distribution (Intramural and Extramural) 4-74
4-22 Relative Size of Intramural and Extramural Workforce 4-75
By Laboratory
7-1 Current Laboratory Structure 7-3
7-2 Structure for Customer Orientation Option 7-5
7-3 FTE by Scientific and Technological Function, Office of 7-7
Radiation and Indoor Air (Customer Orientation Option)
7-4 FTE by Scientific and Technological Function, Office of Air 7-8
Quality Planning and Standards (Customer Orientation Option)
7-5 FTE by Scientific and Technological Function, Office of 7-9
Ecological Systems Research (Customer Orientation Option)
7-6 FTE by Scientific and Technological Function, Office of 7-10
Health Research (Customer Orientation Option)
7-7 FTE by Scientific and Technological Function, Office of 7-11
Environmental Characterization and Monitoring (Customer
Orientation Option)
Xlll
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FIGURE PAGE
7-8 FTE by Scientific and Technological Function, Office of Pesticide 7-12
Programs (Customer Orientation Option)
7-9 Laboratory Directors' Alternative 7-15
7-10 Structure for Carnegie Commission Option 7-18
7-11 FTE by Scientific and Technological Function, National Ecological 7-19
Systems Laboratory (Carnegie Commission Option)
7-12 FTE by Scientific and Technological Function, National Monitoring 7-20
Systems Laboratory (Carnegie Commission Option)
7-13 FTE by Scientific and Technological Function, National 7-21
Environmental Engineering Laboratory (Carnegie Commission Option)
7-14 FTE by Scientific and Technological Function, Office of Health 7-22
and Environmental Assessment (Carnegie Commission Option)
7-15 FTE by Discipline (Degrees), National Ecological Systems 7-24
Laboratory (Carnegie Commission Option)
7-16 FTE by Discipline (Degrees), National Monitoring Systems 7-25
Laboratory (Carnegie Commission Option)
7-17 FTE by Discipline (Degrees), National Environmental 7-26
Engineering Laboratory (Carnegie Commission Option)
7-18 FTE by Discipline (Degrees), Office of Health and Environmental 7-27
Assessment (Carnegie Commission Option)
7-19 Structure for Distinct Environmental Services Organization Option 7-28
7-20 FTE by Scientific and Technological Function, Distinct Environmental 7-31
Services Organization (DESO) Option
7-21 FTE by Discipline (Degrees), Distinct Environmental Services 7-32
Organization (DESO) Option
xiv
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FIGURE PAGE
9-1 Organization Chart for the U.S. Food and Drug Administration 9-4
9-2 Organization Chart for Department of Health and Human 9-13
Services, Public Health Service, National Institutes
of Health, Division of Intramural Research
xv
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EXECUTIVE SUMMARY
The U.S. Environmental Protection Agency (EPA) supports its regulatory mission
through 39 laboratories and other technical facilities across the nation; activities at these
facilities range from enforcement and technical services to development and fundamental
research. The roles and missions of these organizational units have evolved over time as
the focus on environmental problems has shifted from control of pollution from point
sources within separate media to multimedia problems of national and international scope
and to ecological and human health concerns. If EPA's mission is expanded beyond
environmental protection to federal leadership of environmental science, the roles and
responsibilities of its laboratories may have to be realigned and redirected. Recognizing a
possible need for change, Congress directed EPA to "explore whether a consolidated
laboratory structure would better enable the Agency to accommodate the need for
integrated research and monitoring," and "should the study recommend the continuation of
the current arrangement, the report should include a detailed justification for doing so."
The MITRE Corporation was tasked to perform an independent assessment of EPA's
laboratories for use by the Agency as one of the inputs in developing of its report to
Congress. MTTRE's study was guided by a Steering Committee, reporting to the Deputy
Administrator, that was composed of EPA's science advisor and representatives from each
of EPA's offices at the assistant or associate administrator level.
Based upon the broad roles and functions that were assigned to EPA when it was
established in 1970 and upon the additional responsibilities that have been placed on it
through environmental legislation enacted over the intervening years, the main scientific
and technological functions of the EPA mission that are supported by the laboratories are
application-directed research, fundamental research, development, enforcement/
compliance, monitoring, quality oversight, technical assistance and services, technology
transfer, analytical support, state and local oversight, and emergency and episodic
response. Regardless of changes in the organizational structure, these functions must be
maintained at an adequate level within EPA or acquired from other federal or state
agencies or from other organizations.
The scientific and technological base within EPA, as well as other regulatory agencies,
must be built upon four principles:
• Credibility through end-to-end quality assurance
• Timely response to regulatory needs
• Highly skilled and respected professional staff
• Commitment and sustained funding to expand the information base
ES-1
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In addition to reviewing published literature from previous studies, MITRE staff
visited each laboratory to obtain current information on its missions, activities, and
functions; to gain a sense of the status of facilities and equipment; and to discuss with
management and staff operational issues, quality, and the use of the research results. In
parallel with MITRE's efforts, EPA gathered detailed information on staff work activities,
academic degrees, and employment levels through a questionnaire called Workforce '94.
Some of the results of this survey are incorporated into this study. The entire results of
Workforce '94 will be published as a separate report by EPA. Detailed information on
expenditures of appropriated funds, planning, equipment, and facilities for each of the
laboratories was provided to MITRE by offices at EPA's headquarters. Interviews were
conducted with senior management throughout the Agency to ascertain their views on
EPA's laboratories and the research program and also with some internal and external
customers to discern how well the research products and services fulfill their needs.
Currently, EPA's laboratories are organized into three distinct groups:
• 12 laboratories, 4 assessment offices, and 4 field stations within the Office of
Research and Development (ORD) that engage in fundamental research,
application-directed research, development, and technical assistance on an
as-needed basis
• 9 program office laboratories that support regulatory and short-term needs
through laboratory analytical services, enforcement and compliance activities,
monitoring, technical assistance and services, and a limited amount of
development
10 regional environmental services organizations (ESOs) that are dedicated to the
support of regional programs primarily through the provision of laboratory
analytical support, quality oversight, and technical activities in support of
enforcement and compliance
These laboratories vary widely in the number of staff (7-277) and the range of disciplines
(with the dominant fields being chemistry, biosciences, and engineering). They are located
in or near 24 cities throughout the country, and at EPA's headquarters in Washington. In
some cases, facilities and equipment require significant upgrading. Intramural expenditures
for the laboratories in fiscal year 1993 (FY93) were $138 million for ORD, $37.8 million
for the program offices, and $47 million for the ESOs; total intramural and extramural
expenditures in FY93 were $392.5 million, $65.7 million, and $49.4 million, respectively.
Six assistant administrators and ten regional administrators are involved in laboratory
administration and direction; this structure complicates research activities planning and in
many cases separates the laboratories from their major internal customers or users.
ES-2
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With the guidance of the Steering Committee, MITRE identified many options that
would encompass aspects of physical, organizational, or functional consolidation of EPA's
laboratories. Five organizational and functional options were chosen for examination and
assessment without and with physical consolidation:
Customer orientation: focus on program offices as center for science and
technology
• Streamlining: reduction in the number of senior staff, particularly at EPA
headquarters
• Carnegie Commission: emphasize multimedia issues
• Distinct environmental services organization (DESO): centralize responsibility
for all technical support functions
• Geographic location: place-based orientation to environmental issues.
An assessment was made of the changes that could occur in the quality of the
scientific and technological products and in the efficiency and effectiveness of the
operations relative to the current situation. The following list of criteria jointly agreed
upon by EPA and MITRE was used in the assessment:
• Science quality/utility: Does the option facilitate production of science of the
highest quality throughout the Agency to support all facets of its environmental
protection mission?
• Stature/credibility: Does the option provide potential for enhancement of the
professional stature and credibility of the scientific and technological staff?
• Concentration of resources: Does the option permit sufficient concentration of
specialized scientific and technological support resources (e.g., facilities,
equipment, critical skills, critical mass of skills) to conduct high-quality research
and support activities within EPA?
• Geographic location: Does the option provide for reasonable access to resources
necessary to carry out the assigned mission?
• Mission focus: Does the option improve the laboratories' focus on their mission?
ES-3
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• Customer satisfaction: Does the option improve the ability to satisfy customer
needs?
• Use of intramural workforce: Does the option maximize the effectiveness of
the use of EPA's intramural workforce?
Multimedia approaches: Does the option enhance the Agency's ability to
address multimedia interdisciplinary issues?
Priorities: Does the option ensure that resources and organizations are focused
on the highest-priority environmental problems and Agency support needs?
• Functional alignment: Does the option ensure that resources and organizations
are focused on Agency support needs by clarifying organizational responsibilities
and reducing functional redundancy?
• Operating costs: Does the option provide potential cost savings?
• Facilities and equipment: Does the option provide for more efficient use of
resources available for facilities and equipment?
• Future investment: Does the option lead to optimal future investments in
facilities and equipment?
• Locus of control: Does the option resolve the locus of control issues raised in
the study?
Use of human resources: Could the option decrease the number of human
resources required to achieve assigned tasks?
Implementation time: Can the option be implemented in reasonable time with
minimal disruption of key research and support functions?
Implementation cost: Is the cost to implement and maintain the option
reasonable?
Table ES-1 presents a summary of the option evaluations made by the MITRE staff
who visited the laboratories, based upon their interviews with EPA personnel and then-
analysis of the laboratory data. The potential changes that could result from implementing
an option are designated by the symbols in the table. The changes range from strongly
ES-4
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Table ES-1. Evaluation of Options
Option
Customer Orientation w/o consolidation
Customer Orientation w/ consolidation
Streamline w/o consolidation
Streamline w/ consolidation
Carnegie w/o consolidation
Carnegie w/ consolidation
Distinct ESO (DESO) w/o consolidation
Distinct to(J (UtoU) w/ consoHaanon
Geographic w/o consolidation
Geographic w/ consolidation
E
Science Quality/Utility
O
O
O
o
o
+
o
+
+
FECTIVE
Stature/Credibility
O
O
O
o
+
+
+
0
o
USE OF
Concentration of Resources
O
+
O
+
o
++
0
o
+
AGENC
Geographic Location
O
O
O
o
o
o
o
o
++
V RESOl
Mission Focus
+
+
O
O
+
++
+
+
•f
JRCES
Customer Satisfaction
++
4-
O
-
0
o
--
+
+
Use of Intramural Workforce
O
+
+
+
0
+
0
+
+
Multimedia Approach
O
O
O
o
+
+
0
++
++
EFF
Priorities
++
++
O
0
+
+
0
+
+
ICIENT 1
Functional Alignment
+
+
O
0
0
++
0
o
--
JSE OF f
Operating Costs
O
+
+
++
-
+
0
o
--
iGENCY
Facilities and Equipment
0
+
O
+
0
+
0
o
-
RESCUE
Future Investments
O
+
0
+
0
+
0
o
--
tCES
Locus of Control
O
O
+
+
+
++
0
o
o
Human Resources
O
+
O
+
0
++
-
0
-
IMPLfME
Implementation Time
O
-
0
-
-
--
o
-
--
STATION
Implementation Cost
O
-
-
--
O
--
o
o
--
w
in
Ui
Explanation of symbols: -- strongly negative - negative
Note: The relative Importance among the criteria was not considered In the analysis.
o no effect
+ positive
++ strongly positive
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positive, designated by a double plus symbol (++), to no discernible change or a balance
between positive and negative change, designated by a zero (0), to a strongly negative
change, designated by a double minus (--) symbol. The relative importance among the
criteria was not considered in the assessment.
If the options are implemented without physical consolidation, the implementation
time is short, since the changes from the current operations are mainly those of reporting
relationships. Implementation costs would be expected to be substantial for physical
consolidation of the laboratories, but no quantitative estimates of these costs have been
made as yet by EPA or MITRE. Since the Carnegie Commission option affects only the
ORD laboratories, and the DESO option affects only the ESOs, these options should not
be compared.
Among the positive aspects of the options, the Carnegie Commission option with
physical consolidation was evaluated more favorably than any of the other options that
involve ORD. In the areas in which the Carnegie Commission with consolidation was
strongly positive—human resources, mission focus, locus of control, functional alignment,
and concentration of resources—none of the other options that would affect the ORD
laboratories was as positive.
The strongly positive aspects of the Geographical Location option, including its
multimedia approach resulting from place-based ecosystem orientation, could be
implemented under other options as well. This is also true of the strongly positive aspects
of the Customer Orientation option—customer satisfaction and focusing on the highest
priorities of the Agency.
The Streamlining option was neutral for most of the criteria, although it could reduce
operating costs. If the provisions of this option were implemented under either the
Carnegie Commission or DESO option, similar savings could be effected.
The evaluation of the DESO option showed that it could have positive effects on the
stature of the laboratories and the mission focus, although it is strongly negative with a
large loss in customer satisfaction, an area in which the ESOs are now highly regarded.
With consolidation, some savings would be seen in operating, facilities, and equipment
costs, but other benefits are offset by the decline in customer satisfaction. The Geographic
Location option would provide improvements in the area of customer satisfaction, where
the DESO option was very weak.
The option judged to be most negative, Geographic Location with consolidation,
would affect all three types of laboratories. This option was evaluated as strongly negative
for functional alignment—a criterion for which the Carnegie Commission option with
ES-6
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consolidation was judged strongly positive. In the Carnegie Commission option,
consolidation reinforced the functional alignment, while the Geographic Location option
did not. The alignment resulting from the Geographic Location option was perceived as
expensive and not productive; it was seen as having the negative aspects of
relocation—disruption and high costs—and few of the advantages of the Carnegie
Commission option.
The assessments made by MITRE of the restructuring options have been useful in
identifying the major controlling factors that must be addressed by EPA in making its
report to Congress. However, there are further opportunities for EPA to improve the
efficiency and effectiveness of its operations through management changes. Three changes
appear reasonable to MITRE for eliminating the apparent duplications of facilities and
equipment and to increase the disciplinary strengths of the human resource base:
• Consolidation of laboratories in the Office of Prevention, Pesticides, and Toxic
Substances and the two laboratories under the Office of Radiation and Indoor Air
• Realigning and consolidating the ORD laboratories in the manner of the Carnegie
Commission option
• Reducing the number of laboratories within the regional offices through
consolidation to a few laboratories with national service focus.
These changes could be made over time as leases for current facilities expire or
investment decisions on facility and major equipment upgrades are being made.
Five management improvements are recommended to bring about positive changes:
• Establish quality assurance as a visible high-level function
• Perfect the issue-based planning process
• Create a customer orientation throughout the Agency with a clearly focused and
articulated mission statement
• Improve the information management system to increase the accessibility of
managers to complete, consistent, and accurate data
• Delegate authority to the lowest level of management consistent with federal
policies
ES-7
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Many of the findings and observations made in this report are consistent with those
reported over the past 12 years in prior reports on EPA's research or laboratory functions.
With the current emphasis on reengineering within public and private enterprises, it is a
propitious time to build upon this broad base of experience and implement changes.
ES-8
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SECTION 1
INTRODUCTION
1.1 BACKGROUND OF THE STUDY
The U.S. Environmental Protection Agency (EPA) supports its regulatory mission
through an array of laboratory and other technical facilities across the nation. These
laboratories are operated by several offices:
• Office of Research and Development (ORD): 12 research laboratories,
4 assessment offices, and 4 field stations
• Program Offices: 9 laboratories operated by five program offices (Office of
Administration and Resources Management [OARM]; Office of Air and
Radiation; Office of Enforcement; Office of Prevention, Pesticides, and Toxic
Substances; Office of Water)
• Environmental Services Organizations (ESOs): 10 ESOs comprised of
9 environmental services divisions and 1 environmental services branch
These laboratories perform a broad scope of scientific and technological activities that
range from enforcement and technical services to developmental and fundamental
research. The roles and missions of these facilities have evolved over time as the focus on
environmental problems has shifted from control of point sources within separate media to
multimedia problems and ecological and health impacts. The future portends greater
attention to regional, national, and global environmental issues. As emphasis continues to
shift from control and abatement to pollution prevention, additional changes in roles and
missions can be expected. Many of the laboratory facilities are in need of significant
repairs requiring substantial financial resources. Federal staffing within EPA has been
constrained, resulting in heavy reliance on both on- and off-site contractor support and
giving rise to concerns related to potential conflict of interest, personal services
contracting, inappropriate performance of inherently governmental functions, and reduced
ability of government employees to oversee contractors. The number of facilities and the
geographical separation of the laboratories from one another—and often from their
principal customers—also raise questions on the efficiency of the current research and
technical operations. EPA is responding to these concerns by devising a new mode of
operation, as shown by the current emphasis on strategic planning and the streamlining
and self-study initiatives that have been undertaken.
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The objectives of this study are (1) to develop a baseline description of all of EPA's
laboratories and (2) to assess options to enhance the quality, effectiveness, and efficiency
of laboratory operations in order to provide the institutional flexibility needed to respond
to EPA's current and future roles and missions.
The genesis of this study was a budget request to Congress by the EPA Administrator
for funding an external study of the ORD laboratories. The Senate Committee on
Appropriations supported the Agency's request as long as it did not duplicate earlier
efforts and included specific recommendations for change. The Committee required EPA
to explore whether a consolidated laboratory structure would better enable the Agency to
accommodate the need for integrated research and monitoring. The Committee indicated
that continuation of the current arrangement could be considered an option if a detailed
justification for doing so could be provided. Although Congress originally directed EPA to
provide a report by 31 March 1994, the deadline was extended to 30 May 1994.
The Office of Research Program Management (ORPM) in ORD contracted with
The MITRE Corporation for assistance in an assessment of the EPA scientific and
technological laboratories. The study was guided by a steering committee that reported to
the Deputy Administrator and was composed of EPA's science advisor and representatives
from each of EPA's offices at the assistant or associate administrator level. The scope of
the study includes EPA's major research and technical operations, including ORD
headquarters offices, laboratories, assessment offices, and field stations; it also extends
beyond ORD to include the ESOs and all laboratories operated by EPA program offices,
including the National Enforcement and Investigation Center (NEIC). MITRE's study
incorporates the results of recent internal studies of the ORD laboratories, as well as the
results to date of the streamlining efforts now under way at EPA. MITRE has evaluated
the availability of scientific and technological support to accomplish EPA's responsibilities
for environmental protection and leadership and the processes required to fulfill these
responsibilities. The assessment includes (1) a description of the current configuration and
focus of scientific and technological support functions within EPA, (2) an evaluation of
the efficiency, effectiveness, and quality of these functions, and (3) an evaluation of major
options for potential functional or organizational realignment. No attempt has been made
to discuss board policy issues such as what the Agency's emphasis should be between
basic and applied research, or whether the mission of the Agency should be expanded
from environmental protection to include environmental scientific leadership.
EPA employees have shown a high degree of interest and participation throughout the
study. Their cooperation and assistance have been essential in establishing a meaningful
and credible information base of current functions and operations. The ORPM and the
OARM have been responsible for providing much of the data summarized in the tables
appearing throughout this report.
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In addition to the Steering Committee, MITRE received input from the National
Academy of Public Administration (NAPA) and EPA's Science Advisory Board (SAB).
These groups reviewed the Draft Study Plan and Draft Final Report, then provided their
comments to the authors. In addition, the Draft Final Report was reviewed by numerous
staff at EPA; to the extent practicable, their comments have been incorporated in the Final
Report.
The directors of the ESOs formed a work group that provided the study team with
both comments on the Draft Study Plan and materials to facilitate data collection. The
structures of the ESOs vary among regions, with different functions assigned to the
various organizations. To ensure consistent comparisons among the ESOs, the directors
requested that, rather than focusing on just the laboratory, three core functions be used to
define the ESOs. The three core functions—laboratory services, quality assurance and
quality control, and field monitoring—are discussed at length in Section 4. Unless a
specific distinction is made among these three functions, the term "ESO laboratory" will
be used to describe them collectively and the data and information presented in tables and
figures throughout the document will encompass all three core functions. In March, the
ORD laboratory directors established a study team to review and comment on the draft
study and to make a set of recommendations to the Assistant Administrator (AA) for
ORD. Based on the MITRE study results, and the reports of NAPA, SAB, and the two
internal groups, EPA's Steering Committee will formulate a separate set of
recommendations, which will be forwarded to the Administrator, who will present the
Agency's recommendations to Congress.
1.2 EPA ORGANIZATION
The EPA was formed in 1970 by consolidating a variety of programs from other
government agencies. These elements included administrative, regulatory, and research
activities. The laboratories associated with these activities were also incorporated into
EPA. It is not surprising that, even 24 years later, the result reflects the rather disparate
history of many of the EPA laboratory elements.
Laboratories are highly visible, easily identifiable entities, in part because the
laboratory is often in a well-defined location that correlates to the work performed. The
functions of laboratories are not always well understood, in part because of their technical
nature, and in part because laboratory work covers such a wide range of characteristics
from fundamental research to applied research to regulatory support work. As used in this
report, "laboratory" may refer to the physical facility, including staff and equipment, that
perform scientific, technical, and analytical work to further the goals of the Agency. The
work of the laboratory may be controversial. Fundamental research may be directed to an
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issue having great commercial or political importance (e.g., dioxin), while regulatory and
enforcement work may affect highly visible enforcement cases (e.g., hazardous waste
remediation). There are also are a variety of valid ways to organize the laboratories in the
conduct of their varied work. Different organizational arrangements and reporting systems
may make sense depending on what work characteristics are being emphasized.
Finally, some of the historical debate regarding laboratory consolidation and
organization may arise from a confusion regarding concepts. For example, some people
may raise questions about laboratories, when the real issue of concern is the scientific and
technological activities that are (or are not) being performed at the laboratories. Thus, it is
important to remember that different laboratories have different purposes; some
laboratories concentrate on performing analytical work, while others conduct fundamental
or applied research. Issues of consolidation, reorganization, and mission are very different
for each type of laboratory.
Since the formation of EPA, the laboratories have become organized into three distinct
groups:
• ORD laboratories: ORD operates laboratories that engage in both fundamental
and applied research. Each of the laboratories has its own area(s) of expertise,
often reflecting the pre-EPA origins of the particular laboratory. The process
used to set the different research priorities has undergone substantial change over
the life of EPA. Currently, the research priorities are set through an "issue-based
planning" process; however, the Streamlining Report (Foley, February 1994)
suggests that additional changes may be made. Each laboratory director reports to
an office director who, in turn, reports to the AA for Research and Development.
Funding for ORD research derives from lump sums established in the priority
and budget processes, as well as by a limited number of ad hoc agreements with
program offices and interagency agreements with other federal agencies.
Program office laboratories: Each major program office (except for the Office
of Solid Waste and Emergency Response) maintains one or more laboratories
that operate to support the regulatory and short-term research needs of the
program. Generally, the program office laboratories reports to the program office
director.
ESO laboratories: Each EPA region has a laboratory dedicated to the support of
regional programs and regulatory functions. ESOs vary in size and breadth of
activity, reflecting their individual histories, the roles assigned to them by present
and past regional administrators, the environmental needs of the region, and even
the political history. The major activity of most ESOs is in analysis of samples,
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and to a lesser degree in field work to collect either monitoring or enforcement
samples. Each regional laboratory is the major component of an ESO that is a
located in each region. Each laboratory director has line supervision from the
ESO, but must also satisfy his/her regional administrator and other regional
customers.
While most fundamental and applied research in EPA is concentrated in the ORD
laboratories, applied research in support of regulation writing is also performed in the
program office laboratories. Analytical work in support of regulations is concentrated in
the ESOs, although the program office laboratories conduct some of this work as well.
EPA does only a fraction of the environmental research (fundamental and applied)
performed for the federal government. Other agencies, among them the National Oceanic
and Atmospheric Administration (NOAA), the National Institutes of Health (NIH), and the
U.S. Department of Agriculture, carry out their own related research efforts.
Because the activity of laboratories is often highly visible (and expensive), it is
important that the laboratories be organized to achieve a high degree of effectiveness in
the expenditure of the public funds. There has been a long and continuing interest in the
organization of the laboratories. Given the geographically dispersed nature of the EPA
laboratories, an obvious and recurring question is whether consolidation of one form or
another might improve effectiveness. Several types of laboratory consolidation are
possible:
Physical Consolidation: As used in this study, physical consolidation of laboratories
refers to physical closure of a laboratory facility and movement of the people and contents
into another laboratory. A variation on physical consolidation is collocation—two or more
laboratories might be placed on the same or nearby sites, with greater or lesser amounts of
shared overhead. Laboratories sharing the same physical location might be under the same
or different management.
Organizational Consolidation: Another type of reorganization or consolidation of
laboratories would leave the laboratories geographically dispersed but combined at an
organizational or management level. The present ORD laboratories are all in the same
organization and thus are consolidated in the organizational sense. An alternative
organizational consolidation might combine laboratories having similar characteristics.
Such combinations might be by function (fundamental versus applied research), medium
(water versus air), or customers (program offices versus regions).
Functional Consolidation: Consolidation could also be achieved by eliminating
overlapping or redundant functions or activities conducted by several laboratories—for
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instance, the development of special analytical methods (e.g., dioxin)—or by eliminating
of replication of special equipment or facilities that are not fully utilized.
1.3 ORGANIZATION OF THE DOCUMENT
The objectives of the laboratory study as defined by the Study Plan and EPA guidance
are discussed in Section 2. Congress specified that the current study should make use of
earlier studies and, accordingly, several of these are reviewed in Section 3. Section 4
addresses the Agency's mission and its scientific and technological needs; it also presents
summary financial, facilities, human resources, and equipment data; detailed supporting
information for each laboratory can be found in Appendix A, the second volume of this
report. In the course of this study, interviews were held at every laboratory, and the
principal recurring issues have been summarized in Section 5 for each of the three
laboratory types—ORD, program office, and ESO; several state and non-EPA laboratories
were also visited and the results of these reviews are included in Section 5 as well.
Management improvements that could be applied with any structural option to improve
quality, efficiency, and effectiveness are discussed in Section 6. The five structural options
developed for evaluation and the distinguishing criteria are described in Section 7 and
evaluated in Section 8. Section 9 presents three other federal models, and Section 10
evaluates alternative accountability models. The findings of the study are presented in
Section 11, and a list of the previous studies reviewed for this study is located in
Section 12. Highlights of the project schedule are given in Appendix B, and summaries of
the 26 EPA executive interviews conducted to help direct the effort are in Appendix C.
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SECTION 2
OBJECTIVES AND METHODOLOGY
2.1 OBJECTIVES
It is the primary purpose of this study to inform the discussion surrounding the
performance of EPA's scientific and technological mission by examining the structure and
functions of the Agency's laboratories. This study provides the following:
• An extensive set of current, relevant information on EPA's scientific and
technological activities conducted through its laboratories
• A critical assessment of options for enhancing the quality and effectiveness of
laboratory operations
The objectives of this study are as follows:
Assemble an extensive description of the current scientific and technological
missions, laboratory management and operations, human resources, facilities, and
equipment by compiling existing information, reviewing prior studies, and
visiting the laboratories.
• Identify and characterize EPA's needs for scientific and technological
information and its role in providing environmental science products to other
agencies and tiers of government using information gathered from published
plans; interviews with EPA headquarters, program office, and regional
management; and discussions with laboratory management and staff.
• Highlight any significant differences in perspectives of the laboratories of their
missions and EPA's needs for scientific and technological information.
• Perform an objective, but not quantitative, evaluation of the quality of the
laboratories' scientific and technological products, the effectiveness and
efficiency of laboratory operations (human resources, equipment, and facilities),
and the responsiveness of the laboratories' scientific and technological functions
to EPA's needs.
• Identify apparent redundancies in the activities within the laboratory complex, as
well as areas of overinvestment and underinvestment.
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Identify problem areas within the laboratory complex and provide benchmarks
for options assessment.
Identify and assess organizational options for the laboratory complex, taking into
account current and future scientific and technological needs, federal staffing
constraints, human resources profiles, financial resources constraints, prevailing
contracting procedures, and the impact on current and proposed facilities.
2.2 METHODOLOGY
The approach to this study has three related phases, with the later phases building on
the information and understanding developed in earlier phases. These phases logically
begin with the information acquisition phase, followed by the information synthesis phase
and the options development and analysis phase.
2.2.1 Information Acquisition
The information acquisition phase was designed to acquire the information needed to
describe the scientific and technological laboratories within the Agency. During this phase,
specific information on the laboratory mission, functions, products, services, and
customers was obtained. This information helped establish an understanding of the
laboratory's scientific and technological functions, why it is involved in those functions,
and how well it performs those functions, including its interfaces with and relationships to
other EPA organizations. A major element of this phase was the specification of
information needs that provided a basis for determining how efficiently and how
effectively a laboratory carries out its functions. The information also indicates whether
the laboratory's products and services are of high quality as viewed by the laboratory and
its customers.
Information acquisition began with the development of a descriptive framework that
could be applied to the laboratories to aid in capturing their salient features and
characteristics and to describe how the laboratory fits into a general laboratory program
within the Agency. The purpose of the framework was to provide a basis for examining
the characteristics of each of the three types of laboratories—those belonging to ORD, the
program offices, and the regions. Senior executives of EPA were interviewed to identify
issues to be examined in developing the framework. Summaries of these interviews are
given in Appendix C.
Information was acquired through existing EPA documents and interviews at the EPA
laboratories and regional offices, as well as state laboratories and private industrial
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laboratories. Prior to the visits, a set of discussion topics designed to elicit information
was sent to laboratory personnel scheduled to be interviewed; these topics provided the
interviewees an opportunity to consider their responses before the interview. Interviewers
were aided in their information collection task by an "interview guide" that helped ensure
consistency in the information acquisition process. The data collected from the office and
laboratory visits contributed to defining the features and characteristics of each laboratory.
The individual elements were interpreted and synthesized to develop a description of the
EPA laboratory system as a whole. The descriptive information that was acquired is
essential both for characterizing the state of the overall laboratory program and for
estimating the impact that various options might have on the program's efficiency and
effectiveness. While some of the information that was acquired might not be immediately
applicable for the purposes of this study, it was important to EPA to have this consistent
snapshot of all the laboratories at the same point in time.
All of the original data in the tables in Appendix A was obtained from EPA.
Information on the demographic characteristics and work activities of the laboratory staff,
including activity distributions, numbers and types of degrees, and age distributions, was
obtained from the Workforce '94 database. (Workforce '94 was a survey of all laboratory
and ORD Headquarters staff conducted independently by ORPM during the course of this
study.) Numbers of full-time equivalent (FTE) staff were provided by ORPM for ORD
laboratories and by individual laboratories for the program office laboratories and ESOs.
The number of extramural work-years used by each laboratory was also provided from the
Workforce '94 database, while facilities data was provided by the OARM Facilities
Management and Services Division (FMSD) and by individual laboratories. Equipment
data was provided by OARM through ORPM from the PPAYS equipment inventory
database. The data in the activity/function matrices was provided by the individual
laboratories. Laboratory financial data was provided by ORPM for ORD laboratories and
by the individual laboratories for the program office laboratories and ESOs. FMSD
provided OARM Buildings and Facilities (B&F) expenditures data.
2.2.2 Information Synthesis
During the second phase, information synthesis, a profile was obtained of the current
laboratory situation in terms of its missions and functions, products, services, customers,
and operational characteristics (including organization, management, staffing, and
facilities). This profile provides a qualitative assessment of each laboratory's effectiveness
and efficiency, as well as the quality of its products and services.
Data acquired through the laboratory visits was used to form a laboratory information
database, which was structured to accommodate the elements of the descriptive framework
as attributes. This structure facilitated synthesis of the information in aggregated form and
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aided in the evaluation of the current laboratory system. A great deal of information on
the laboratories was gathered that is not included in this report. The information that did
not directly relate to this study nevertheless provides EPA with contemporaneous
information on all of the laboratories.
Activity/function matrices, developed by MITRE staff, were presented during the visits
to the laboratories. These matrices were filled out with the percent or number of FTEs and
extramural funds associated with each activity and returned to MITRE. The laboratories
could add or delete any of the activities; each laboratory determined which of the
functions the activities should be assigned to. The individual matrices are included with
the laboratory descriptions in Appendix A, and summary tables are discussed in Section 4.
2.2.3 Options Development and Analysis
In the options development and analysis phase, options for organizational restructuring,
functional realignment, and other management considerations were developed and
analyzed. The laboratory profile or baseline, developed in the previous phase, served as
the basis for comparing the options. Six options were described in the Study Plan for this
effort; these options have been changed and recombined, and based on previous studies
and other discussions, assumptions have been developed for each of the five options
presented in this study. Issues discussed at each of the laboratories were consolidated into
four major categories, as discussed in Section 5. The options were evaluated against
criteria developed from these issues, as well as other criteria suggested by the Steering
Committee to determine the impacts of implementing each option. EPA is preparing cost
analyses for the options, and these will be considered, along with the option analysis,
during the Agency's preparation of recommendations to Congress.
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SECTION 3
RECENT STUDIES RELEVANT TO EPA RESEARCH
OR LABORATORY FUNCTIONS
3.1 PAST STUDIES OF EPA LABORATORIES
Since EPA was created in 1970, a variety of internal and external groups have
conducted numerous studies of EPA's research activity and laboratories. Some of these
studies were the result of EPA initiative, while others resulted from Congressional or
other outside direction. This section will summarize and discuss some of these studies.
While some of the previous studies focused on the physical condition of the
laboratories and capabilities of the work force or on the fiscal benefits of consolidation,
most have concentrated on how research priorities are set and whether the research mix of
the laboratories is optimal. As a result, most of the studies and debates have centered on
the ORD laboratories; however, it is important to remember that there are other
laboratories present in EPA, and that, in addition to ORD laboratories, others do conduct
applied research.
Table 3-1 shows a selection of the major studies of the EPA laboratories and/or
research functions since 1982. To simplify the discussion, a "short name," often used by
others in referring to the reports, has been designated. The full name and source of each
study is given in the bibliography in Section 12. The studies are presented in reverse time
sequence.
The only study that deals in detail with the issues surrounding physical consolidation
of all three types of EPA laboratories is the 1982 consolidation study and its 1985 follow-
up. These two studies evaluated the cost and program implications of a wide variety of
possible consolidations, with the primary goal being to reduce costs. While some of the
findings and recommendations were implemented, most were not. For example, although
the study considered reducing the number of regional laboratories, in recent years, several
of these laboratories have been upgraded, relocated, or expanded. The record does not
offer precise reasons for these decisions, but it is apparent that a variety of program,
policy, and political factors affected the decisions to provide a suitable laboratory for each
EPA region.
Several studies have examined the broader issues related to the research and service
balance and priorities in the EPA laboratories, especially in the ORD and program office
laboratories. These studies include the National Institute for the Environment (NIE),
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Table 3-1. Past Studies Affecting EPA Laboratory Activities and Organization
Short Name
Streamlining
Aging
Laboratories
NIE
Fundamental
Research
The Third
Decade
NRC
Carnegie
Report
Expert Panel
NAPA
Future Risk
Laboratory
Organization
SAB
Consolidation
Committee
Full Title
Redesigning Research at EPA: Proposed Changes to Mission,
Organizational Structure, and Streamlining in the
Office of Research and Development
Federal Research: Aging Federal Laboratories Need
Repairs and Upgrades
Reinventing our Environmental Research Enterprise
Report to Congress: Fundamental and Applied Research
at the Environmental Protection Agency
EPA Organization for Environmental Research: The Third
Decade (Report to Congress)
Research to Protect, Restore, and Manage the Environment
Environmental Research and Development: Strengthening
the Federal Infrastructure
Safeguarding the Future: Credible Science, Credible Decisions.
Report of Expert Panel on the Role of Science at EPA
EPA's Office of Research and Development: Leadership and
Staff for a New Agenda.
Future Risk: Research Strategies for the 1990s
EPA Laboratory Organization (memo)
Science Advisory Board Annual Reports
Laboratory Consolidation Committee Draft Report (memo)
Date
02/94
09/93
06/93
02/93
01/93
-793
12/92
03/92
07/90
09/88
07/85
00/94
07/82
Author
Foley/ORD
GAO
Committee for the
National Institute for the
Environment (NIE)
EPA7ORD
ORD
NRC
Carnegie Commission
Expert Panel on the Role
of Science at EPA
NAPA
Science Advisory Board
Science Advisory Board
Consolidation Committee
Coverage
Review of ORD research organization
and policy
Review of U.S. government laboratory
racilities including EPA
Proposal for National Institute for the
Environment. Covers all federal,
environmental research.
Compilation of ORD resource
expenditure
History of ORD
Review and recommendations on
overall federal environmental research
and organization
Review and recommendations on ORD
research organization and policies
Review and recommendations on ORD
research and work force policies
Internal EPA review of consolidation
and reorganization issues
Annual reports of the SAB to the EPA
Administrator
Review and recommendations on
consolidation alternatives for all EPA
laboratories.
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National Research Council (NRC), Carnegie Commission, Expert Panel on the Role of
Science, and NAPA studies. Several of these studies are concerned with federal
environmental research; EPA is only one component of these studies.
The SAB Annual Reports provide additional information. The SAB was established by
Congress to advise the EPA administrator on scientific and policy issues. It reviews
particular technical issues for EPA and also develops issues of its own. In general, its
reports indicate a fairly high level of approval of the work of EPA, with occasional
specific criticisms. However, in its Fiscal Year 1992 (FY92) report, the SAB reviewed the
President's budget for ORD and concluded that "insufficient funds and FTEs pose a
serious threat to the continued viability of the EPA research program." The SAB went on
to raise some major concerns including (1) excessive reliance of on-site contractors for
research, (2) attrition of federal career scientists, and (3) increasing obsolescence of
equipment and facilities. These observations are relevant to the current study.
The previous studies have somewhat different findings and recommendations, but all
show a high degree of concern with the present research priorities at EPA. Thus, taking
into account the experience with the consolidation efforts in the early 1980s, the major
concerns are not related to the marginal cost savings possible from consolidation, but
rather to the issues of management and policy. Therefore, the laboratories cannot be
evaluated without addressing the policy issues, nor from an evaluation of management in
addition to structure.
To help establish the background for the present study, each of the earlier studies is
described in some detail, and the findings and recommendations are summarized. These
discussions and their supporting tables do not list all the findings and recommendations of
the reports, only those that are most relevant to the present evaluation. In some cases, the
reports and studies did not provide explicit listings of findings, or the findings were not
directly related to recommendations. Where appropriate, findings have been inferred from
the text or recommendations, and this fact is noted. In many cases, the findings or
recommendations have been paraphrased so that they would be easier to compare. Quotes
are used whenever extensive portions of the original text are provided. Finally, in a
number of places, some interpretation of some of the findings has been provided,
especially where they apparently conflict with another study or the present evaluation.
3.1.1 The Expert Panel Report
In May 1991, the EPA administrator appointed an expert panel to provide "a set of
recommendations for how...[EPA]...can best meet the goal of using sound science for its
decision making." The expert panel held public meetings, interviewed more than
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30 individuals from EPA and other governmental and non-governmental agencies, and
accepted more than 25 written comments.
The report states that it uses the term "science" broadly to include a wide range of
technical activities such as research and development, as well as technical and regulatory
support. This includes the "...scientific activities conducted by EPA program, policy, and
regional offices...." However, because the report focuses on the role of science in EPA
decision making, the report inevitably concentrates on ORD, while other parts of the EPA
laboratory system receive less attention. For example, the interrelationship of the programs
at the ORD and the program office laboratories, and the role of the ESOs receive less
attention.
Tables 3-2a and 3-2b show a summary of selected findings and recommendations most
relevant to the laboratory evaluation in the present report.
3.1.2 The National Academy of Public Administration Report
The NAPA Report was prepared by a panel in the National Academy of Public
Administration. The report notes that in 1988 EPA's SAB recommended that EPA give
"increased attention to longer-term issues relating to preventing and reducing
environmental risk...and to reorient its [ORD] program to include more basic, long-term
research not necessarily tied to the immediate regulatory needs of EPA's program
offices...." This report, requested by ORD, was intended to provide a review of the
progress on carrying out the recommendations. The panel met four times during the study.
Panel members and staff interviewed over 100 individuals in EPA, visited 13 of the
15 laboratories and field sites and interviewed all laboratory directors, and met with a
variety of other EPA staff, Human Resource Councils within EPA, and the chairperson of
the SAB.
The NAPA Report found that many steps had been taken to implement their
recommendations. However, it also found that impediments to progress had become
apparent in some areas. The report found a substantial degree of confusion concerning the
direction and mission of ORD, even though it found that substantial progress toward a
stronger basic research program had been achieved.
One irony of the report is that these items of progress—improvement in the strength of
the basic research program—are found to conflict several years later with the need for
increased regulatory program responsiveness found in the Streamlining Report and in
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Tables 3-2a and 3-2b. Safeguarding the Future: Credible Science, Credible Decisions
Report of Expert Panel on the Role of Science at EPA, March 1992
#
Finding
"EPA does not have a coherent science agenda and operational plan to guide scientific
efforts throughout the agency and support its focus on high-risk environmental problems.
"EPA has not clearly conveyed to those outside or even inside the Agency its desire and
commitment to make high-quality science a priority [in decisions]."
"The development and nurturing of human resources are central to improving science at
EPA."
"... [EPA] lacks the critical mass of externally recognized scientists needed to make EPA
science credible to the wider scientific community."
"...Problems in the [EPA] approach to academic grants and centers have discouraged many
university-based experts from working with EPA... [all EPA] laboratories often rely on
contractual mechanisms that prevent EPA from obtaining the best outside scientists...."
#
Recommendation
"The [EPA] has moved in the right direction with its new issue-based planning process.
EPA should further develop this process...[and] apply to science throughout [EPA]...."
"For ORD scientists, the Panel recommends continued attention to appropriate science and
science management career tracks. For scientists in [other] offices...[establish] a science
career track similar to that in place for those providing legal advice...[EPA] should
enhance rotational opportunities...."
"EPA should recruit four to six world-class research scientists or engineers...."
"EPA should move quickly to bolster its grants and centers program. [EPA]...should
implement a long-term plan to replace contractual mechanisms that may be detrimental to
obtaining the best possible scientific information."
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MTTRE's interviews with potential ORD customers. Another irony is the observation that
"even with the formalities required by the federal procurement regulations, EPA [ORD]
laboratories have successfully integrated extramural and federal staff...." The results of the
MITRE interviews showed widespread frustration with the contracting process only four
years later. Similarly, the report found good morale in ORD, yet interviews several years
later show a significant level of frustration in the staff. These apparent changes appear to
result from a combination of different interview and data compilation techniques, changes
in programs and policies in ORD in the interim, and new constraints under which staff
members work (especially in procurement and contracting).
Tables 3-3a and 3-3b list a selection of the findings and recommendations of the
NAPA Report that are relevant to the present study.
3.1.3 The Carnegie Report
The Carnegie Report was prepared by the Carnegie Commission on Science,
Technology, and Government, and it was sponsored by the Carnegie Corporation of New
York. The study considers the entire federal effort in environmental research. The
Carnegie Commission worked with staff of the American Association for the
Advancement of Science. The basis of the study included personal knowledge of the
environmental research structure on the part of Commission and staff members, as well as
fiscal and budget studies of federal environmental research. The study did not include
extensive visits of EPA laboratories or extensive discussions with EPA staff.
The central concern of the study was that there should be sufficient, high-quality
scientific knowledge to understand and respond effectively to the environmental
challenges facing the United States and the world. The report advocates a stronger, more
unified approach to identifying and responding to the nation's environmental issues.
Because the report addresses overall federal environmental research and organizational
structure, many of the recommendations apply outside EPA. The report did not explicitly
evaluate either the program office or the ESO functions of EPA.
Table 3-4 shows selected recommendations from the Carnegie Report that are relevant
to the present study.
3.1.4 The Streamlining Report
The Streamlining Report was prepared by ORD staff in response to a directive from
the President, as administered by the EPA Administrator. The Streamlining Report
reviewed for MITRE's study covered only ORD and does not reflect the internal concerns
of the other EPA laboratory components (the program office and ESOs), nor does it
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Tables 3-3a and 3-3b. ORD: Leadership and Staff for a New Agenda
The NAPA Report, July 1990
Finding
1
"[The ORD] is a confederation of office and research laboratories...[reflecting] its ancestry
in...individual agencies...."
2
"The difficulties of conducting high quality research in a regulatory organization...[are very
great]...research...requires a degree of isolation...[with]...a long-term focus...[but] a regulatory agency
such as EPA operates in a political world of short-term mandates...."
"The individual nature of each [ORD] laboratory...creates a situation in which there is limited staff
interest in moving among ORD components...The lack of staff mobility... militates against the creation
of a common culture and operating style...."
"...ORD poses an exceptionally demanding set of leadership tasks. Administrators generally remain
with the organization two years or less [i.e., the turnover rate of administrators is an especially serious
problem]
5
"[staff turnover is very low]...and if anything, is seen as a significant [problem since it has]...prevented
hiring new staff to replace an aging work force."
6
"High [leadership turnover] and longevity of [field] staff have...reinforced the view that continuing
survival of [a particular] laboratory can best be attained though independent leadership and laboratory
agenda setting...."
"Considerable differences [among the staff] still exist concerning future directions expressed by the
[SAB report]."
"[staff expressed] criticism of the quality and coherence of ORD communications."
#
Recommendation
1
"...a—reappraisal [is needed] for the suitability of the current research committee function and
process...."
2
"...a short, substantive statement [is needed] that broadly outlines the direction in which...ORD must
move....
3
"...initiate a full assessment of all ORD Planning Processes, with a goal of developing a concerted
strategic planning effort that engenders scientific creativity and effective management...."
4
"...establish criteria for using extramural staff rather than continue the current ad hoc situation. These
criteria should indicate that ORD will...always maintain in-house technical capability."
5
The panel had numerous recommendations regarding aggressive recruitment of minorities,
improvement of in-house training and promotion, improved personnel appraisal systems, and the
possible need to hire scientists of "national stature."
"...recommends that ORD institute a comprehensive 'visiting committee" evaluation of each laboratory
on a two- to three-year cycle..."
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Table 3-4. Environmental Research and Development
Carnegie Commission, December 1992
#
Recommendation
"An Institute for Environmental Assessment (TEA) should be established...to
evaluate global and national environmental problems... the IE A could be located in
the Executive Office,...EPA,...or a Department of Environment...."
"The EPA's existing [research] laboratory structure, now composed of
12 laboratories, should be consolidated to create:
• National Ecological Systems Laboratory
• National Environmental Monitoring Systems Laboratory
• National Environmental Engineering Laboratory
• National Health Effects Research Laboratory"
"EPA should establish...up to six major Environmental Research Institutes
associated with academic institutions and non-governmental organizations."
"A new US Environmental Monitoring Agency (EMA)...combining National
Oceanic and Atmospheric Administration and the U.S. Geological Survey...EMA
would include a National Center for Environmental Information."
consider in detail interlaboratory relationships between ORD and program office
laboratories. It does, however, discuss potential customer relationships of program offices
with ORD in relation to setting research priorities. Related streamlining studies have been
prepared for the various program offices, including the program office laboratories, but
these studies have not been reviewed for the present evaluation. The purpose of this
Streamlining Report was to identify methods of improving ORD's effectiveness and
efficiency while reducing the number of supervisory staff. The ORD study was very much
a grass-roots effort, involving committees and individuals throughout the ORD, both at
headquarters and in the laboratories.
While potential supervisory staff reduction was a highly visible component and goal of
the study, the study emphasized the additional steps needed to achieve a more desirable
mix of fundamental and applied research within ORD. In addition, it suggested ways to
improve the quality and quantity of research performed by the ORD staff through
decentralization and empowerment techniques.
Tables 3-5a and 3-5b show a summary of the findings and recommendations most
relevant to the present study. A summary is not able to communicate the high degree of
detail and specificity reached in many of the findings and recommendations.
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Tables 3-5a and 3-5b. Plan for Reinventing and Streamlining ORD
February 1994
# Finding
"There is a strong sense that the ORD mission needs to be clarified...by people in
ORD and...outside of ORD...."
"Since [EPA] was...established there has been a tension between the need to make
immediate decisions about protecting the environment, and the need for adequate
information on which those decisions could be based. Over the years, different
views...have predominated...."
"The current administrative system is generally perceived to be inefficient and often
ineffective, and not producing the desired results...staff feel increasingly hamstrung by
excessive administrative requirements...."
"ORD has a unique opportunity..because of the number of people who are going to be
eligible to retire in the next two years...and the contractor conversion process...."
# Recommendation
"Consider replacing the current HQ ORD offices and replacing them with mega-labs,
as recommended by the Carnegie Commission, or alternatively, eliminating the
current Offices and having Laboratory Directors report directly to an Associate
Administrator for R&D."
"Convert from "traditional division-branch-section structure...[to] project team[s]" [for
both bench research and management]."
"[Establish] two...career tracks: one of in-house research, and one of extramural
project management."
"Separate strategic [fundamental] research from program support research...."
"...develop a long-term strategic hiring plan...[to help implement many changes in
staffing]."
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3.1.5 The National Institute for the Environment Report
The ME report (more accurately termed a "proposal") was prepared by the Committee
for the National Institute for the Environment, a private body advocating the establishment
of a national institute for the environment. This institute would be designed to "improve
the decision making on environmental issues" through the administration and coordination
of research into environmental issues. The proposal envisions the institute as a priority-
setting coordination agency, rather than as an agency with its own laboratories and staff of
researchers. It would not conduct, establish, or enforce regulation.
The NIE Report is relevant to the present study because it envisions a different
mechanism for coordinating research and possibly allocating research funding. This
approach could affect the fundamental research role of ORD, and possibly the applied
research role of both ORD and the program office laboratories.
Tables 3-6a and 3-6b show a summary of the findings and recommendations of the
Nffi Report.
3.1.6 The National Research Council Report
In 1993, the Committee on Environmental Research of the NRC issued a report
discussing federal environmental research programs. The study concentrated on the way
science is used in environmental decision making and provided recommendations for
improvements in environmental research and the use of the scientific knowledge obtained.
In preparing the report, the committee consulted with federal officials, received briefings,
and held a public hearing receiving testimony from over 100 persons.
The NRC Report recommends a series of "cultural" changes in the conduct and use of
environmental science, and it presents alternative organizational "frameworks" to
accomplish these cultural changes. The cultural changes recommended include both goal
statements and certain organizational modifications. The alternative frameworks provide
differing methods for implementing the remainder of the recommended changes. One of
these frameworks is very similar to the NIE proposal discussed above.
Tables 3-7a and 3-7b show a summary of the findings and recommendations of the
NRC Report.
3.2 CONCLUSIONS DRAWN BY PREVIOUS STUDIES
Previous studies of research by ORD, EPA, and the federal government have resulted
in a variety of findings and recommendations. Some of the findings identified symptoms,
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Tables 3-6a and 3-6b. Proposal for the National
Institute for the Environment, August 1993
#
Finding
1
"...critical gaps in [environmental system]
understanding continue to stymie decision making..."
2
"...federal environmental research structure...lacks an
overall perspective that can answer our...needs for
high-quality information...."
#
Recommendation
Establish the National Institute for the Environment
with the mission to "improve the scientific basis for
making decisions on environmental issues...."
The NEE should "manage four integrated functions:
• Competitively sponsor credible research on key
environmental problems
• Continually assess current knowledge to
identify deficiencies and set priorities
• Actively facilitate access to information for
policymakers, professionals, and the public
• Innovatively educate...and train new types of
scientists, engineers...."
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Tables 3-7a and 3-7b. Research to Protect, Restore, and Manage the Environment
National Research Council, 1993
Finding
1
"There is no comprehensive national environmental research plan to coordinate the efforts of...[the
agencies].."
2
"The nation's environmental efforts have no clear leadership...the U.S. has lacked strong commitment
to environmental research...."
3
"Bridges between policy, management, and science are weak...."
4
"Long-term monitoring and assessment of environmental trends and the consequences of...regulations
are seriously inadequate...."
5
"Research on engineering solutions to environmental problems is seriously underfunded...."
6
"...the government operates in a strongly adversarial relationship with industry and the general
public...."
"With exceptions in the NSF, NOAA, and USGS, most federal environmental R&D is narrow,
supporting either a regulatory or a management function...."
Recommendation/Alternative Framework
A National Environmental Plan (NEP) should be developed to [coordinate] environmental research...of
federal agencies.
A National Environmental Council (NEC) in the...office of the President should be established to
provide leadership...."
An Environmental Assessment Center (EAC) must be established to assess large environmental issues
that cross agency mission boundaries...."
A National Environmental Status and Trends Program...should be initiated...to inventory and monitor
the status...of the nation's natural resources.
A National Environmental Data and Information System should be established to collect...[and
disseminate]...data.
Separate research and regulatory functions within EPA
7a
Framework A: Maintain current organizational structures. Establish NEP and NEC. Enhance programs,
and increase basic research with extramural projects
7b
Framework B: Create National Institute for the Environment (NIE) to focus solely on environmental
research, assessment, information management, and higher education and training. NIE would NOT
incorporate existing agencies.
7c
Framework C: Establish National Institute for Environmental Research (NIER) to focus on same issues
as NIE. However, it WOULD subsume most of NOAA, part of NASA, and the research component of
EPA.
7d
Framework D: Create Department of Environment, to include EPA, NOAA, USGS, and part of NASA.
It would incorporate research (as with NCER) and regulatory activity.
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while others focused more closely on underlying problems. Some recommendations in the
studies described desired changes in end behaviors of organizations, while others gave
more detailed descriptions of specific modifications to programs, priorities, or
organizational structures to accomplish such changes.
However, in spite of the very different methodologies and orientations of the studies,
all have contributed to an understanding of the problems and issues surrounding research
at EPA and, to a lesser extent, laboratory operations themselves. The studies tended to
focus either on fundamental research at ORD or on government-wide environmental
research issues and policy. Few studies examined the non-ORD laboratory operations in
detail or focused on details of the interrelationships among all of the laboratories. A
number of the findings identified similar areas of concern although they provided very
different recommendations for solutions.
The findings from the whole range of studies (not just those discussed above and in
the tables) deemed most relevant to the present evaluation are summarized below. Many
of the problem areas have been addressed by EPA and, at least in part, have been
corrected in the past several years. However, it is clear that many areas remain subjects of
concern by persons both inside and outside of EPA and that there continue to be
significant differences of opinion regarding problems and solutions.
Research Balance. There was concern about the balance between short-term and long-
term research, as well as the balance between fundamental and applied research and the
relevance of the research in supporting EPA's mission. Findings include the following:
• Some studies believed that there is insufficient research on long-term issues and
that work is biased by a "pollutant of the month" effect.
• Some studies viewed ORD as too independent (i.e., not sufficiently sensitive to
regulatory needs), while others view ORD as not sufficiently independent (i.e., too
dependent on regulatory needs to the detriment of the long-term research program).
• Research to support policy and regulatory decisions should be improved; the
credibility and relevance of EPA science in these areas is questioned.
• The research committee structure is awkward and leads to rigid research priorities.
(Note: The issue-based planning process has superseded the research committee;
while eliminating some problems, it has created others.)
• EPA is not perceived to be committed to the best science in policy and decisions,
especially early in the regulation-developing process.
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Research Quality. Findings raised the following concerns about the quality of the
research done:
• Peer-review processes are not uniform.
• There is a need to upgrade staff through exchange programs, cooperative programs,
training, and so forth.
• Reduction in funding for staff, laboratory facilities, and equipment has reduced
quality.
• Insufficient resources are available to maintain staff competence, especially for
non-bench scientists.
• Quality and quantity of instrumentation are below industrial standards.
• Excessive extramural research has reduced stimulation and feedback of EPA staff.
Results cannot be documented for review, forming the basis of regulatory
challenges.
Multiple Laboratory Site Effects. Concerns have been raised about the use of multi-
site laboratories. These include the following:
• There is concern that each of the ORD laboratories is in competition, leading to
insufficient attention to long-term Agency-wide priorities.
• The ORD laboratories have a large variety of operating styles, including the
balance of extramural and intramural research.
• The geographic distribution of the laboratories makes program management of the
laboratories more complicated.
Extramural Issues. Concerns were raised about the balance of intramural and
extramural research, including the types and quantity of the work. These concerns include
the following:
• Too much extramural work is done, leading to weakness in the EPA staff.
• The EPA should expand the amount of extramural research.
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• Recent studies appear to show serious problems with the procurement and
contracting process. Procurement is found to be too complex and time-consuming,
while contract administration has become too complex, reducing the productive
time of scientists.
Human Resource Development. Several personnel policy issues were identified,
including the following:
• ORD has a technical ladder. This needs to be enhanced, and other laboratories
should institute such ladders for their scientific staff.
• The ORD has a low turnover rate and a high proportion of white male researchers.
This implies a relatively low rate of introduction of new ideas and people. Many
ORD laboratories have researchers in a relatively narrow age cohort, leading to
concerns about loss of experience when the cohort retires.
• There is a lack of uniformity in application of personnel policy and procedures.
Compensation. One study found that compensation levels were not a major problem
in the research area.
Leadership. One study identified the rapid turnover of ORD leadership, especially in
the first 15 years of ORD, as a major contributor to organizational problems.
3.3 SUMMARY OF PREVIOUS STUDIES
A variety of studies have been conducted to evaluate the research quality and service
delivery of the EPA laboratories; some of these studies have focused on EPA, while
others have evaluated the overall federal environmental research effort. While all of the
studies offer insights into the laboratory operations and research policies of EPA, none
have had the direct focus of the present study—to evaluate all of the EPA laboratories,
both from a policy and an operations point of view. The studies have widely varying
major and minor findings and disparate recommendations; however, all indicate a high
level of concern that the research and regulatory support policies of the EPA are not well
balanced, and that there remains a relatively high level of confusion as to the most
appropriate roles for the EPA laboratories.
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SECTION 4
CURRENT LABORATORY MISSIONS AND OPERATIONS
4.1 SCIENTIFIC AND TECHNOLOGICAL MISSIONS
4.1.1 EPA's Mission
In the Message of the President, which accompanied Reorganization Plan No. 3 under
which the EPA was established in 1970, the roles and functions of EPA were specified to
include the following:
• The establishment and enforcement of environmental protection standards
consistent with national environmental goals
• The conduct of research on the adverse effects of pollution and on methods and
equipment for controlling it, the gathering of information on pollution, and the
use of this information in strengthening environmental protection programs and
recommending policy changes
• Assisting others through grants, technical assistance, and other means in arresting
pollution of the environment
• Assisting the Council on Environmental Quality in developing and
recommending to the President new policies for the protection of the
environment
As part of the ongoing National Environmental Goals project, EPA's Office of Policy,
Planning and Evaluation has conducted internal roundtables and has produced a draft
analysis of EPA responsibilities in protecting the environment (U.S. EPA, Draft, 23 March
1994). This report summarizes 13 major statutes that form the legal basis for the EPA
programs; the 13 statutes are summarized below:
• Pollution Prevention Act states that it is the policy of the United States that
pollution should be prevented or reduced at the source whenever feasible;
pollution that cannot be prevented should be recycled in an environmentally safe
manner whenever feasible; pollution that cannot be prevented or recycled should
be treated in an environmentally safe manner whenever feasible; and disposal or
other release into the environment should be employed only as a last resort and
should be conducted in an environmentally safe manner.
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Clean Air Act (CAA) gives the states specific deadlines for meeting the air
quality standard and requires states and the federal government to make constant
progress in reducing emissions. It requires technology controls on air toxics to be
achieved within 10 years of enactment (2000). It requires a permanent
10-million-ton/year reduction in sulfur dioxide emissions from 1980 levels and a
2-million-ton/year reduction in nitrogen oxides from 1980 levels. It establishes
dates for phasing out ozone-depleting substances: 2000 for chlorofluorocarbons,
halon, and carbon tetrachloride; 2002 for methyl chloroform; 2030 for
hy drochlorofluorocarbons.
Clean Water Act has as its objective the restoration and the maintenance of the
chemical, physical, and biological integrity of the nation's waters.
Ocean Dumping Act declares that it is the policy of the United States to
regulate the dumping of all types of materials into ocean waters and to prevent
or strictly limit the dumping into ocean waters of any material that would
adversely affect human health, welfare, or amenities, or the marine environment,
ecological systems, or economic potentialities.
Safe Drinking Water Act directs EPA to develop national drinking water
regulations for public water systems, underground injection control regulations to
protect underground sources of drinking water, and groundwater protection grant
programs for the administration of sole-source aquifer demonstration projects and
for wellhead protection programs.
Solid Waste Disposal Act (SWDA) and Resource Conservation and Recovery
Act (RCRA) declare it to be the national policy of the United States that,
wherever feasible, the generation of hazardous waste is to be reduced or
eliminated as expeditiously as possible. Waste that is nevertheless generated
should be treated, stored, or disposed of so as to minimize the present and future
threat to human health and the environment.
Comprehensive Environmental Response, Compensation, and Liability Act
(CERCLA) (Superfund) provides for liability, compensation, cleanup, and
emergency response for hazardous substances released into the environment and
the cleanup of inactive hazardous waste disposal sites. The 1986 amendments to
the Superfund law required EPA to begin physical, on-site cleanup of at least
175 new (after 1986) sites by 1989, and at another 200 sites within the following
two years. There are no deadlines for finishing this work.
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• Emergency Planning and Community Right-to-Know Act requires local
planning to cope with chemical emergencies and ensures that responsible
officials are provided with information from local businesses about their
activities involving hazardous chemicals. This act mandates the development of a
national inventory of releases of toxic chemicals from manufacturing facilities,
which is called the Toxic Release Inventory (TRI). The purpose of the TRI is to
provide information to the general public about chemicals to which they may be
exposed.
• Toxic Substances Control Act (TSCA) states that authority over chemical
substances and mixtures should be exercised in a manner that would not impede
unduly or create unnecessary economic barriers to technological innovation while
fulfilling the primary purpose of this act—to ensure that such innovation and
commerce in such chemical substances and mixtures do not present an
unreasonable risk of injury to health or the environment.
• Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) regulates the
marketing of economic poisons and devices.
• Environmental Research, Development, and Demonstration Authorization
Act authorizes all EPA's research and development (R&D) programs.
National Environmental Education Act states that it is U.S. policy to establish
and support a program of education on the environment through activities in
schools, institutions of higher education, and related educational activities, and to
encourage postsecondary students to pursue careers related to the environment.
• National Environmental Policy Act has four purposes: to declare a national
policy that will encourage productive and enjoyable harmony between man and
his environment; to promote efforts that will prevent or eliminate damage to the
environment and biosphere and will stimulate the health and welfare of man; to
enrich the understanding of the ecological systems and natural resources
important to the nation; and to establish a Council on Environmental Quality.
In summary, the provisions in these acts and the Reorganization Plan require EPA to
do the following:
Identify environmental and human health problems
• Understand fundamental natural processes controlling impacts on the
environment and health
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Understand specific mechanisms of environmental or health damage
Develop approaches to counter harmful influences or promote environmental
enhancements
Develop regulatory tools to implement environmental and health protection
strategies
Monitor progress and provide assurance that environment and health are
adequately protected
Share information with other organizations and institutions, and with the public
EPA's mission activities can be grouped into four broad elements, shown in Figure 4-1:
• Research
• Regulation
Response to emergencies
• Information dissemination
These broad mission elements have been translated by legislation and court decisions
into specific Agency roles and obligations, that together represent the working-level
definition of the Agency mission. In Figure 4-1, designed by MITRE, the main elements
of the EPA mission are reduced to operational components that must be supported by the
offices and the staff of the Agency in order to accomplish the mission. These operational
components define EPA's requirements for scientific and technological support in order to
fulfill its mission. The EPA laboratories have stated missions that, it can be shown,
support this hierarchy of mission elements.
Figure 4-1 places environmental protection as the highest purpose of EPA; subsidiary
mission elements fall out from that. It has been suggested that the Agency mission ought
to be expanded to include environmental scientific leadership along with environmental
protection and certain suggestions for reorganizing the laboratories are aimed specifically
at enhancing the Agency's scientific leadership role. The elements of EPA's mission
might not be altered thereby, but the relative emphasis on them would change and
presumably the allocation of resources as well.
The program offices, as a rule, are the main consumers of scientific and technological
support within the Agency.
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Environmental Protection
Conduct
Research
Fundamental
Research
Applied
Research
- Measurement Technology
Abatement/Remediation
Technology
Regulate
Contamination
Develop
Standards
Monitor, Inspect,
and Enforce
Standards
Permit/ Register/
Certify
Implement
Voluntary
Programs
Support
Environmental
Response
Operate
Operate/Control
Prepare for and Respond
to Emergencies
- Remediate
Investigate and Recover
Costs
Enable
Support Community
Relations
-Train and Certify
Provide
Information
Technical
Environmental Data Users
Negotiators
Coregulators
General
r Policy Makers
•-General Public
Figure 4-1. Mission of EPA, Showing Derivative Operational Components
-------
4.1.2 Scientific and Technological Functions
EPA addresses its scientific and technological requirements through activities that can
be grouped under a number of scientific and technological functions. These functions were
identified and defined in the Study Plan and were agreed upon by the Steering Committee.
The functions described below have been used throughout the study as the principal
means to organize the information gathered with respect to the laboratories.
Application-Directed Research: Research directed to the solution of defined
problems, based on existing scientific understanding, where such solutions may involve
the creation of new processes, procedures, methodologies, or situations that will serve a
practical or useful purpose.
Examples include construction of pollutant fate models, laboratory-scale
characterization of pollutant degradation processes, formulation of ecological risk
assessment frameworks, integration and evaluation of information on pollutant effects and
exposure to estimate risks to human populations or ecosystems, and creation of new
monitoring or measurement methods.
Fundamental Research: Theoretical or experimental investigations to advance
scientific knowledge where such knowledge is relevant to understanding the environment,
pollution, or human health, but immediate practical application is not a direct objective.
Examples include mechanisms of chemical carcinogenesis, functioning of ecosystems,
biosensors for pollution monitoring, the use of computers and theoretical understanding to
predict a chemical's fate in the environment, understanding and quantifying the reactions
that determine the persistence of organic chemicals, pharmacokinetics, mechanisms of
bioavailability, and clinical and animal studies of the mechanisms of toxicity.
Development: The work required to bring a new process, technique, methodology, or
piece of equipment to the production or application stage.
Examples include field calibration and testing of models that predict movement of
chemical constituents in the environment, field validation of monitoring methods,
pilot/field optimization of sediment and aquifer remediation processes, and pilot-scale
optimization of control technologies.
Enforcement/Compliance: Application of technical knowledge and methods to
support enforcement/compliance activities to determine conformance with regulations and
permits.
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Examples include facility compliance inspections, compliance sampling inspections,
criminal and civil enforcement investigations, emergency response support, and state and
contractor oversight.
Monitoring: The application of skills, techniques, equipment, and facilities primarily
for determining ambient conditions or status and trends of the environment, including
quality assurance (QA) and quality control (QC) activities associated with monitoring.
Examples include sample plan design, collection, analysis, data validation and interpre-
tation, data management, special studies, contract management, and report preparation.
Quality Oversight: This function consists of QA and QC.
• Quality Assurance is an integrated system or program of activities involving
planning, quality control, quality assessment, reporting, and quality improvement
to ensure that a product or service meets defined standards of quality with a
stated level of confidence.
Examples include auditing processes to ensure that planning, implementation, and
assessment activities are conducted according to approved documentation.
• Quality Control is an overall system of routine technical activities for the
purpose of measuring and controlling the quality of a product or service so that it
meets the needs of the user.
Examples include development of data quality objectives, definition of sample
collection protocols, definition of the number of QC/reference samples to be
incorporated into the analytical runs, laboratory and field audits and inspections,
and sample analysis.
Technical Assistance and Services: Transferral of technical information to customers
such as EPA program offices, other federal agencies, states, tribes, foreign governments,
international agencies, academia, the general public, and others.
Examples include interpretation and application of existing knowledge to rule-making
activities, answers to policy questions, expert testimony, experimental design, expert/peer
review and comment, training, and response to environmental emergencies; removal
programs under the Superfund program; special-purpose environmental assessments that
address problems within a region; and assisting state and local agencies in enhancement of
their abilities to accept delegated authority.
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Technology Transfer: Technical activities that involve dissemination of new
technological information to (1) potential users at the regional, state, local, and
international levels, (2) the general public, and (3) the regulated community. This may
include technical document editing or production.
Examples include technology demonstrations and support of licensing of intellectual
property.
Analytical Support: Full spectrum of routine and special analytical testing services
that support specific media program activities, inherently governmental functions, and
regional management priorities using Agency-approved methodologies.
Examples include analytical services that measure physical, chemical, microbiological,
and biological parameters mandated by SWDA; Clean Water Act/Water Quality Act;
Marine Protection, Research, and Sanctuaries Act; CAA; FIFRA; RCRA; TSCA; and
CERCLA/Superfund Amendments and Reauthorization Act in all types of media.
State and Local Oversight: Review and management of state and local grants and
cooperative agreements and contracts in support of Agency-wide monitoring and cleanup
programs.
Examples include oversight of State 105/106/305B/319 grants, Superfund Contract
Laboratory Program, Superfund contractors, interagency agreements, and Superfund and
RCRA data validation activities.
Emergency and Episodic Response: In-house, multi-disciplinary scientific and
technological capabilities necessary to provide quick, flexible responses to a broad range
of media program priorities and hazardous episodes.
Examples include rapid deployment of emergency and investigation personnel and on-
site laboratory support providing quick analytical turnaround.
Table 4-1 illustrates the relationship of these scientific and technological capabilities to
the mission of the Agency. Supporting the four broad mission elements are the operational
components, each component requiring scientific and technological support. This table
was derived by asking which scientific and technological functions are necessary to
successfully perform each mission element. The scientific and technological support needs
for each of the four broad mission areas and the subsidiary mission elements are briefly
outlined below; scientific and technological functions are indicated by italics.
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EPA_LAB.XLS
Table 4-1. EPA Mission Elements Linked to Scientific and Technological Functions
Scientific &
Technological
Functions
Application-Directed
Research
Fundamental Research
Development
Enforcement
Compliance
Monitoring
Quality Oversight
Technical Assistance &
Services
Technology Transfer
Analytical Support
Slate/Local Oversight
Emergency & Episodic
Response
EPA Mission Elements
Conduct Research
Funda-
. . Applied
mental r
X
X X
X X
X X
X
X
X X
Regulate Contamination
Monitor,
Inspect. Permit/ Implement
o. Vj j and Register/ Voluntary
Standards ... „ ,. '
Enforce Certify Programs
Standards
X X O
X
X X O O
X X
X
X X X O
X X X X
X
X X
X X
X
Support Environmental Response
Prepare for
. Investigate
„ , and r Support T ,
Operate/ ... and . Train and
_ , Respond to Remediate „ Community _ „
Conlrol K Recover „ , „ Certify
Emer- „ Relations
, Costs
gencles
X X O
X
XXX X
X X X X
XX X
X X X X X
XX XX
X X X X
X X
X XX
Provide Information
Envlr Data Policy
Users, Makers.
Negotiators, General
Coregulalors Public
X X
X X
X Major Requirement
O Minor Requirement
-------
Conduct Research
EPA's environmental research includes fundamental research to explore open issues
regarding fundamental processes, measurement concepts, and impacts of contamination on
human health and the environment; conducting fundamental research requires a
fundamental research capability in terms of staff qualifications, facilities, work
environment, and budgetary timeframe. Other scientific and technological needs for
supporting fundamental research include quality oversight (for internal and external peer
review of the scientific product) as well as monitoring and analytical support capabilities
for those research projects requiring data collection and/or sample analysis.
Applied research is needed to ensure that the measurement and remediation/
abatement technologies that could logically flow from conducting fundamental research
are realized. A strong applied research program benefits from direct access to the
fundamental research capability that can provide a fundamental understanding of the basic
science issues underlying the application. Quality oversight is needed for internal and
external peer review, while monitoring and analytical support capabilities are essential
scientific and technological functions for those applied research projects needing them.
Technical assistance and services needed for support of applied research include inter-
and intra-laboratory communications for providing access to the basic researchers.
Effectiveness of applied research requires that some technology transfer process be in
place to ensure that the resulting technology is publicized and made available.
Regulate Contamination
In its role as regulator of contamination and the processes and practices that lead to
contamination, EPA carries out four basic activities, each calling for a range of scientific
and technological support. In conducting its mission to develop standards, EPA requires
access to fundamental and applied research capabilities to provide the scientific and
technological basis for creating a new standard. Fundamental research is likely to be of
major importance when dealing with standards affecting human health; applied research is
needed to ensure the feasibility of measuring the targeted species in the regulated
environment. Development capabilities ensure the availability of the instrumentation, test
facilities, and models needed to implement and enforce the standard. A quality oversight
capability is needed to ensure an accurate and credible quantitative analysis when
developing new standards. Access to technical assistance and services capabilities is
needed to provide the necessary scientific and technological feasibility assessments.
The part of EPA's mission calling for the Agency to monitor, inspect, and enforce
standards calls for availability of a wide range of scientific and technological services.
Both application-directed research and development capabilities are needed to provide this
4-10
-------
mission element with the measurement methods needed to enforce new regulations.
Monitoring capability is needed to support enforcement, while quality oversight support is
needed to sustain challenges to enforcement actions. The need for expert testimony
exemplifies the need for technical assistance & services, while regional enforcement
activities require analytical support. State and local oversight support is needed for
dealing with programs delegated to local governments, while emergency & episodic
support may be useful if information gathered during such support activities could be
useful in subsequent legal actions.
Regulating contamination requires that EPA permit/register/certify operations,
processes, and personnel involved in regulated activities and operations. To sustain this
mission element, EPA requires access to application-directed research and development
capabilities to support the development of measurement and certification tools—for
example, the development of instrumentation and test procedures to support automotive
emissions testing. Enforcement and Compliance capabilities are required for a host of
compliance monitoring and testing functions (e.g., automotive emissions testing). There is
a need for a quality oversight capability to certify the quality of data submitted by
regulated parties (e.g., data furnished by the states to show that the Air Quality Control
Regions meet National Ambient Air Quality Standards) and for a technical assistance and
services capability to address questions and issues raised by permit writers and applicants.
The need for analytical support capability arises from the requirements for testing samples
to ascertain violations and/or health threats. State and local oversight capability is needed
for dealing with cooperative agreements and shared/delegated responsibilities.
To implement voluntary programs, EPA may need access to its development
capabilities for such purposes as sustaining the technological basis for the programs.
Quality oversight can provide assurances to the public of the quality of the volunteer
program (e.g., the quality of Radon detectors). Technical assistance and services
capabilities could be employed to provide expert consultation on the voluntary programs,
while technology transfer capability might be called for in the joint publication of
voluntary program products.
Support Environmental Response
Under this mission area, EPA must prepare for and respond to emergencies. Both
application-directed research and development capabilities are needed to support the
preparation for rapid and effective response to potential emergencies. Monitoring
capabilities are needed to track, assess, assure safety, etc., during emergency episodes.
EPA needs technical assistance and services capabilities to provide technical support to
all the other involved parties hi an episode, including state and local governments and the
public. Technology transfer capability is needed to assist with the transfer of technical
4-11
-------
information and expertise within the response teams, to outside technical organizations,
and to governmental and public organizations. The rapid turnaround of test results
required to characterize an emergency demands the availability of a dependable analytical
support capability.
Supporting environmental response calls for an EPA capability to remediate
environmental problems. To sustain a remediation capability, the Agency requires a
fundamental research capability to establish basic understanding of environmental
processes and effects, including ecological and human risk. Both application-directed
research and development capabilities are needed to build the methods, techniques, tools
and procedures needed to effect the remediation. Monitoring and quality-assurance
capabilities are needed to support planning, measurement of progress, and assurance of
safety. The technical assistance and services capability supports contractors, PRPs, and
others, and provides expert testimony associated with the remediation aspects of and
environmental response. EPA must be able to disseminate techniques, technologies, and
methods, and must be able to communicate its actions to the general public, all of which
calls for a strong technology transfer capability. There is a need for routine analytical
services capability to support every phase of the remediation effort. A state/local
oversight capability is required for dealing with situations involving delegated programs.
Another aspect of EPA's mission element to support environmental response is the
requirement that EPA be in a position to investigate and recover costs. To fulfill this
mission element, the Agency needs access to both application-directed research and
development capabilities to provide essential field and laboratory techniques, tools, and
procedures for fingerprinting wastes and disposers. Strong monitoring and quality
oversight capabilities and needed to support the investigation of recovery cases and to
ensure legal defensibility. A technical assistance and services capability may be needed to
support expert witnesses while an analytical services capability serves to support the
investigation and building of cases.
A key element for success in this mission area is EPA's ability to support community
relations. To support this activity, EPA needs a monitoring capability to enable it, with
accuracy and credibility, to inform and reassure the public. Technical assistance and
services and technology transfer capabilities serve to facilitate the transfer of scientific
information, methods, and interpretations to community agencies, groups, and the public,
while an analytical support capability enables EPA to inform and reassure the community.
An emergency and episodic response capability is required to provide the public with
essential and credible information in a timely manner.
EPA must be able to train and certify personnel and contractors who are to be
involved in environmental response efforts. The need for training tools and methods
4-12
-------
requires EPA access to a development capability. A quality oversight capability is needed
to support laboratory certification. Technical assistance and services and technology
transfer capabilities are needed to support the flow of information needed for training,
both within and outside the Agency. State and local oversight capability is needed to
support EPA's training and certifying of state laboratories and technicians. To support the
development of training courses for emergency response, EPA needs access to an internal
emergency and episodic response capability.
Provide Information
The Agency is called on to provide technical and general information to a varied
audience. Technical information is needed by coregulators (state and local officials),
contractors, negotiators, and policy makers, while general information is needed to inform
and reassure the public. To support this information dissemination mission element, EPA
needs access to technical assistance and service and technology transfer capabilities to
provide the desired information in a credible, understandable, and timely manner.
Table 4-1 illustrates the linkage between top-down analysis of the Agency mission and
the bottom-up enumeration of actual activities since both are tied explicitly to the list of
scientific and technological requirements. While there are no surprises in this table, it does
illustrate that the scientific and technological activities performed by the laboratories
respond to legitimate Agency needs. It does raise some interesting questions, however.
How are these scientific and technological requirements being met now? Are needs being
met in each environmental medium? Can they be met in the future, given staff and budget
erosion? Could some or many of them be met better or at lower cost by extramural
sources? To what extent are the laboratories already aligned according to these scientific
and technological requirements, and could they be better aligned? Could fewer
laboratories accomplish the same functions adequately?
4.2 EPA'S LABORATORY ORGANIZATION
4.2.1 Current Organization
The EPA laboratories—some inherited when former government agencies were
combined to create EPA and some created under EPA itself—support the execution of
these mandates described above. The current laboratory structure is illustrated in
Figure 4-2, where it is apparent that the management and reporting relationships are
widely distributed throughout the Agency. The total number of FTEs in the OPJD
laboratories is shown in Figure 4-3, while the total number of FTEs in the program offices
4-13
-------
i
i
. i i
Regional
Administrator
(10)
1 .
L
t
^
t
Environmental
Services
Organizations
- New England
Regional
Laboratory,
Lexington, MA
- Edison, NJ
- Central Regional
Laboratory,
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-Athens, QA
- Chicago, IL
— Houston, TX
- Kansas City, KS
- Denver, CO
- Richmond, CA
L Seattle, WA
Assistant Administrator
for Air and Radiation
Office of Radiation
and Indoor Air
UNAREL
L- ORIA/LV
Office of Air Quality
Planning and
Standards
"—Emission
Measurement
Laboratory
Office of Mobile
~ Sources
L-NVFEL
Associate Administrator
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and State/Local
Relations
Office of Environmental
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Research
Administrator
- ERL/GB
- ERUATH
ERL/DUL
— L*rg* Laktf Rttearch
Station (Or o«u lie, Ml)
-ERL/ADA
-ERL/COR
-ERUNARR
' — Pacttlc Eccxyttomt
Branch (Newport, OR)
Office of Health
Research
'-HERL/RTP
Office of Exploratory
Research
Office of Research
Program Management
Science Aclvisoi
1 1
Assistant Administrator Assistant Administrator
for Research and for Prevention, Pesticides,
Development and Toxic Substances
Assistant Administrator
for Water
1
Office of Modeling, _,_ , _ ,. , ,
Monitoring Systems °'fice o( Pesticide
and Quality Assurance Programs
-AREAL
— PMQ1 /
L-En
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0
L-EMSL/
1 Office of Groundwater
and Drinking Water
^RTP -Environmental LTSD/CIN
LV Chemistry Laboratory
Dtoijaphlc Interpretation LaboratorV
Tter (Wammton, VA) i-auoraior y
~l>. *— Microbiological
Laboratory
Office of Environmental
Engineering and
Technology
Demonstration
UAEERL/RTP
L- RREL/CIN
1 — R»l«at«t Control Branch
(EdUon, NJ)
Assistant Administrator
for Administration and -
Resources Management
"—Data Processing
Laboratory
Assistant Administrator _
for Enforcement
1
1 1 1
Office of Health and of(ice o(
- Environmental L Enforcement
Assessment
-ECAO/1
-ECAO/
'—Human
Group
Office
Ev
FUP
CIN
ire Assessment Group
Health Assessment
LNEIC
Assistant Administrator
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Emergency Response
of Science,
and Regulatory
aluatJon
Note: Laboratories are shown In bold type
Figure 4-2. Current Laboratory Structure
-------
[ACT-REV2.XLW]figures 4-3, 4-4 Chart 1
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Figure 4-3. Number of FTE Staff (FY94)
ORD Laboratories
-------
and ESOs is shown in Figure 4-4. The number of employees at the laboratories ranges
from several hundred in a few of the laboratories to less than fifty in about half of the
laboratories.
While the laboratory reporting structure for program offices and ESOs is fairly direct,
the reporting structure for ORD is far more complex. The program offices report to their
respective headquarters functions directly, and the chain of command is straightforward.
ESO laboratories vary slightly from region to region, but, for the most part, reporting is
done through the Environmental Services Division to a regional administrator. ORD has a
complex reporting structure at the headquarters level that is described below.
The AA for R&D is responsible for the development, direction, and conduct of a
national program of research, development, and demonstration. Within that office are
located the following organizations:
• Office of Research Program Management (ORPM) has primary responsibility for
budgeting, accountability, financial planning and review, management of human
and other resources, and policy development and analysis. In 1994, 61.5 FTEs
were assigned to this office, with the effort split mainly between the activities of
research program planning and management, and administrative support.
• The Office of Science, Planning and Regulatory Evaluation (OSPRE) acts as an
integrator and disseminator of ORD information products to the program offices,
regional office, and other users inside and beyond the Agency. OSPRE manages
the issue-based research planning process, and has a current FTE ceiling of 32.9.
• The Office of Exploratory Research (OER) manages the Agency's anticipatory
and extramural grant research effort. OER identifies the Agency's long term
environmental research concerns; forecasts emerging and potential environmental
problems and manpower needs; and reviews, awards, and manages grants. The
1994 FTE ceiling for OER is 20.4.
The AA's office also includes two Offices of the Senior Official for R&D, one
for Research Triangle Park (RTP) and another for Cincinnati (CIN). The primary
role of these offices is coordination and outward communication for ORD
laboratories located in those geographic areas. These offices have 1994 FTE
ceilings of 8.6 (CIN) and 9.0 (RTP).
• The Risk Assessment Forum is allocated a ceiling of 8.8 FTEs
4-16
-------
[ACT-REV2.XLW]figures 4-3, 4-4 Chart 2
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The total ceiling associated with these offices is 168.4 FTEs.
The ORD laboratories and assessment offices report to the AA for R&D through an
additional five offices. These offices typically perform a full range of functions required
to manage the laboratories under them: needs identification, priority setting, resource
allocation, planning and budgeting support, and quality reviews. These five offices are as
follows:
The Office of Modeling, Monitoring Systems and Quality Assurance
(OMMSQA) includes a Quality Assurance Management Staff, responsible for
Agency-wide quality assurance policies; a Modeling and Monitoring Systems
Staff; and a Program Operations Staff. These oversee and support the
Atmospheric Research and Exposure Assessment Laboratory at RTF and the
Environmental Monitoring Systems Laboratories at Cincinnati and Las Vegas.
OMMSQA also manages the Environmental Monitoring and Assessment Program
(EMAP). For 1994, the headquarters FTE ceiling is 30.
• The Office of Environmental Engineering and Technology Demonstration
(OEETD) is responsible to the Assistant Administrator to ensure the timely
availability of pollution control technology. OEETD includes a Program
Development Staff and a Program Management Staff, with a ceiling of 28 FTEs.
These oversee the Air and Energy Engineering Research Laboratory at RTF and
the Risk Reduction Engineering Laboratory in Cincinnati.
The Office of Environmental Processes and Effects Research (OEPER) includes
a Program Operations Staff, a Terrestrial and Ground Water Effects Staff, and a
Marine, Freshwater, and Modeling Staff, with a ceiling of 24.5 FTEs in 1994.
OEPER oversees the efforts at the Environmental Research Laboratories at
Athens, GA; Duluth, MN; Narragansett, RI; Ada, OK; and Gulf Breeze, FL.
The Office of Health Research (OHR) includes a Health Research Management
Staff, with a ceiling of 11.7 FTEs in 1994. These provide headquarters
management of the Health Effects Research Laboratory in RTF.
• The Office of Health and Environmental Assessment (OHEA) manages the
activities of the Environmental Criteria and Assessment Offices at Cincinnati and
RTF, and provides a concentration of assessment resources under one
organizational umbrella. The 1994 ceiling for OHEA is 17.6 FTEs
The total 1994 FTE ceiling allocated to these five offices is 111.8. The total FTE
ceiling for the headquarters functions of the AA for R&D is 280.2 FTEs.
4-18
-------
4.2.2 Missions of the Laboratories
The mission statements of the individual laboratories are provided in Appendix A. The
missions of the ORD laboratories apply to carrying out R&D needs for the EPA program
offices and an integrated R&D program for the Agency. ORD participates in the
development of EPA policy, standards, and regulations. It provides for dissemination of
scientific and technological knowledge, including analytical methods, monitoring
techniques, and modeling methodologies. It serves as coordinator for EPA's policies and
programs concerning health and environmental effect and ensures appropriate quality
control and standardization of analytical measurement and monitoring techniques used by
EPA.
The individual ORD laboratories carry out these missions, with particular emphasis on
the regulatory and scientific aspects of the missions. The dichotomy of the mission focus,
and the question of which is paramount, is one of the major issues for the ORD
laboratories. Since the ORD laboratories are charged with providing R&D for the program
offices, although they do not report directly to the program offices, the linkages between
the missions of the laboratories and the missions of their clients, the program offices, may
not be distinct.
The basic mission of the program office laboratories is to provide technical support to
assist in regulatory development and enforcement in the mission areas of their parent
program offices. Because the program office laboratories receive direction from clients
who are in their chain of command, the understanding of their missions is very clear.
Each of the ten EPA regions has a laboratory to provide analytical services and
technical support to the regional program offices and their customers. In addition to the
laboratories, the scientific and technological functions within the ESOs include quality
assurance and quality control, and field monitoring functions that are essential to the
Agency's mission. Unless otherwise qualified in the text, the term ESO will include all
three functions.
To a great extent, the current organizational (ORD, program office, and ESO)
groupings of EPA laboratories reflect a focus of their resources on different scientific and
technological functions. To illustrate this point, Figure 4-5 shows the distribution of
laboratory activities, measured in FTEs, among the scientific and technological functions.
A further breakdown of FTEs by function in the ORD laboratories is shown in Figure 4-6
and Table 4-2, in program office laboratories in Figure 4-7 and Table 4-3, and in ESOs in
Figure 4-8 and Table 4-4.
4-19
-------
FTE LABT.XLC
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100
200
Total FTE
580*
534
1535
Number does not include 60 FTE In Region 10
not classified by S&T function.
300
FTE
400
500
600
Figure 4-5. FTE by Scientific and Technological Function by Laboratory Type
-------
FTESTORD.XLC
Application-Directed Research
Fundamental Research
Development
Enforcement/Compliance
Monitoring
Quality Oversight
Technical Assistance
Technology Transfer
Analytical Support
State/Local Oversight
S&T Function Emergency Response
FTE
Laboratory
Figure 4-6. FTE by Scientific and Technological Function
ORD Laboratories
-------
[ACT-REV2.XLW]tables 4-1. 4-3,4.5
Table 4-2. Function Distribution of EPA Laboratories
ORD Laboratories
Laboratory
ORD/AREAL/RTP
ORD/EMSL/CIN
ORD/EMSL/LV (Incl. EPIC)
ORD/EMSL/LV/EPIC
ORD/AEERL/RTP
ORD/RREL/CIN
ORD/RREL/RCB/EDIS
ORD/HERL/RTP
ORD/ERL/GB
ORD/ERL/NARR
ORD/ERL/COR
ORD/ERL/NARR/PEB
ORD/ERL/ADA
ORD/ERL/DUL/LLRS
ORD/ERL/ATH
ORD/ERL/DUL
ORD/ECAO/CIN
ORD/EAG/DC
ORD/ECAO/RTP
ORD/HHAG/DC
Function Distribution of
Application-Directed Research
34%
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30%
26%
36%
42%
38%
25%
44%
40%
23%
35%
37%
41%
69%
21%
39%
58%
31%
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2%
5%
3%
11%
34%
53%
46%
32%
33%
32%
13%
47%
25%
46%
10%
25%
9%
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17%
11%
47%
22%
13%
6%
6%
4%
7%
8%
14%
11%
2%
11%
5%
27%
Enforcement/Compliance
1%
3%
1%
1%
3%
Monitoring
11%
1%
19%
1%
10%
2%
5%
2%
0%
7%
Quality Oversight
10%
19%
4%
17%
13%
5%
1%
6%
7%
21%
3%
10%
Work
Technical Assistance
0%
10%
10%
78%
19%
16%
15%
11%
1%
2%
3%
15%
16%
18%
3%
4%
14%
23%
17%
30%
Program (1)
Technology Transfer
Analytical Support
1%
2% 16%
4%
9%
19%
6%
1% 3%
1%
7%
2% 8%
4%
4%
6%
2%
1%
State/Local Oversight
Emergency Response
5%
2%
1%
1%
1%
2%
(1) FTE-weighted average of laboratory activity/function data. See Appendix A, Table 1 (each laboratory).
Source (original data): Laboratory Directors
4-22
-------
FTESTPRO.XLC
to
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Fundamental Research
Development
Enforcement/Compliance
Monitoring
Quality Oversight
Technical Assistance
Technology Transfer
S&T Function Analytical Support
State/Local Oversight
Emergency Response
Laboratory
Figure 4-7. FTE by Scientific and Technological Function
Program Office Laboratories
-------
[ACT-REV2.XLW]tables 4-1, 4-3, 4-5
Table 4-3. Function Distribution of EPA Laboratories
Program Office Laboratories
Laboratory
OAR/NAREL/MONT
OAR/OAQPS/EMB/RTP
OAR/ORIA/LV
OAR/OMS/NVFEL/AA
OE/NEIC/DEN
OGWDW/TSD/CIN
OPP/ECL/BSL
OPP/ACL/BELTS
Function Distribution of Work Program (1)
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Source (original data): Laboratory Directors
4-24
-------
FTESTREG.XLC
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Figure 4-8. FTE by Scientific and Technological Function
Environmental Services Organizations
-------
[ACT-REVZXLW]tables 4-1, 4-3,4.5
Table 4-4. Function Distribution of EPA Laboratories
Environmental Services Organizations
Laboratory
R01/NERL/LEX
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R03/CRL/ANN
R04/ESD/ATH
R05/ESD/CHI
R06/ESD/HOU
R07/ESD/KAN
R08/ESD/DEN
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Function Distribution of Work Program (1)
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01
*£
"co
u
.c
o
CD
h-
j_
.CP
CO
c.
co
f-1
en
_0
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c
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o
CD
1—
•c
o
Q.
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Zl
CD
"co
0
^*
co
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~m
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CD
CO
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CD
DC
^
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CD
D)
CD
LU
18% 18% 10% 0%
4% 1% 21% 14% 18% 11%
1%
1%
5%
27%
28%
24%
38%
24%
6% 1%
17% 11% 8% 26% 8% 3%
5% 10% 22%
28%
6%
21% 1% 11% 23% 14% 6%
8% 13% 6% 23% 8%
4% 20% 16% 9% 11% 6%
3% 12% 8% 18% 3%
4% 2% 24% 25%
3% 5% 18% 2% 6% 12% 3%
28%
53%
28%
42%
6%
4%
16%
5% 4%
(1) FTE-weighted average of laboratory activity/function data. See Appendix A, Table 1 (each laboratory).
Source (original data): ESO Directors
4-26
-------
ORD's FTEs focus on application-directed research, fundamental research, and
development. Most of the development and application-directed research functions are
dominated overwhelmingly by the ORD laboratories, and all fundamental research is
conducted by the ORD laboratories. As Figure 4-6 illustrates, this is a consistent picture
across almost all ORD laboratories, and the sum of these application-directed research and
development activities exceeds the resources devoted to fundamental research.
Within the program office laboratories, the highest level of effort is devoted to
enforcement/compliance, technical assistance, and analytical support. Apart from a smaller
scale of activities, the pattern of program office laboratory activities looks remarkably
similar to that of the ESOs. The pattern is fairly consistent across all of the program
office laboratories. Only the Office of Mobile Sources' National Vehicle Fuel Emissions
Laboratory (NVFEL) at Ann Arbor and the Office of Ground Water and Drinking Water's
(OGWDW's) Toxic Substances Division in Cincinnati report a significant fraction of their
effort in development or application-directed research. Taken together, these data suggest
that many common scientific and technological functions are performed by two distinct
laboratory types, focusing perhaps on different aspects of the mission, but nonetheless
reporting to a large variety of independent organizations, the associated program offices,
and the ten regions.
To execute its mission as defined by new legislative mandates, the Agency typically
must translate generalized health, ecological, and welfare goals into quantitative and
enforceable standards, and must back those up with data, analysis, methods, technologies,
and procedural guidelines. The offices charged with these tasks require direct, close
support from the best scientific and technological assets of the Agency. This support is
required to evaluate current scientific understanding of a problem and to assess the
capabilities of current technologies to measure and control the target phenomenon. The
development, application-directed research, and fundamental research functions are the
source of this support.
The scientific and technological functions associated most closely with the
development phase of mission execution are technical assistance (to the program offices),
monitoring, development, and application-directed research. Referring to Figure 4-7, it
may be seen that the program office laboratories devote resources to the first two
categories (in some degree as part of implementation), but devote almost none of their
resources to development and application-directed research.
The three functions showing the highest number of FTEs within the ESOs are
analytical support, enforcement/compliance, and technical assistance. It should be noted
that ORD laboratories provide as much technical assistance as the ESOs and program
office laboratories combined. A consistent clustering may be seen among the scientific
4-27
-------
and technological functions other than fundamental research, application-directed research,
and development. The only exceptions are small amounts of effort in Regions 2, 5, and 10
devoted to application-directed research and to development, much of which is devoted to
the methods development required to adapt generalized methods and practices to local
situations. There is no real pattern in the distribution of effort among the scientific and
technological functions across the ESOs.
It is reasonable to expect that the laboratory missions and their activities can be
justified directly by support to the mission of the Agency, as translated from legislative
mandates into an array of scientific and technical requirements. Even for fundamental
research, the customer could be regarded as the program office or other organization
charged with meeting a specific legislative mandate. MITRE's interviews with the ESOs
and the program office laboratories consistently revealed a consensus in line with this
view—the most important customer is the program office or regional program office that
is attempting to execute the Agency mission. However, some interviews with the ORD
laboratories offered a very different view. ORD scientists consider the scientific
community, academia, and the general public as a whole to be clients with at least as
much importance as the program offices that are implementing the laws.
The lack of ORD laboratory focus on program office needs, where it exists, can be
explained by two observations from the MITRE data collection effort. First, the work and
clientele of many of the ORD laboratories is varied; this works against strong partnerships
with program offices. Second, some ORD scientists expressed what may be a common
opinion that they, as senior scientists, know much better than program office personnel or
particular issue planners what type of research needs to be conducted for the best long-
term benefit of the Agency mission.
Thus, scientific and technological functions that are vital to the program offices are
provided by laboratories that answer to an independent chain of command, and include the
competing long-term research function. This approach of organizing activities under an
independent chain of command could be effective, if that organization served to identify
and meet the needs of program office customers as precisely, directly, and inexpensively
as feasible. If, on the other hand, that organization has a view of itself as an independent
R&D organization planning and executing its program in response to its own conception
of the work that needs doing, it will inadvertently introduce barriers between the program
office clientele and the close-support science resources that the program offices require to
do their job. This will be exacerbated if the R&D organization answers to another
clientele for important functions.
It was noted above that METRE has found concern in the program offices with the
focus of ORD laboratory activities intended to support their regulatory development
4-28
-------
functions. This may be predicted from the above, since ORD management attempts to
mediate the demands of program offices on its laboratories by inserting the issue-based
planning process. That process encompasses, under the issues, work both in support of the
program offices and the long-term research phase (aimed at a more universal scientific
clientele, and perhaps more highly valued by the scientists on staff). Further, the issue-
based planning process is longer term in its perspective than the day-to-day scientific and
technological support needs of the program offices frequently are. These circumstances
can be expected to inhibit the direct service ORD laboratories can provide to their
program office customers, and thus to the Agency's execution of the development phase
of its mission.
4.2.3 Laboratory and Mission Alignment
The linkage between EPA's missions and the scientific and technological functions
was discussed in Section 4.1 and the results are shown in Table 4-1. Information obtained
from the laboratories permits identification of the linkages between the scientific and
technological functions addressed by the laboratories and the environmental problems
encompassed by EPA's mission. These linkages are shown in Table 4-5. Most of the
environmental problems are being addressed by at least one laboratory and in some cases
a number of laboratories are actively engaged. It is noteworthy that no laboratory is
performing application-directed research on multimedia problems, and that none of the
laboratories are engaged in application-directed research or fundamental research, or
provide state and local oversight on pesticides.
4.3 ACTIVITY PLANNING
Within the functions described in Section 4.1 lie the individual projects and tasks
performed by the various laboratories and core ESOs. Planning for and assignment of
these projects and tasks varies among the three types of laboratories.
4.3.1 ORD and Issue-Based Planning
The process differs greatly for the ORD laboratories. Their projects and tasks now
originate from a planning process conducted within EPA known as issue-based planning.
Beginning with an overall strategic planning effort, ORD has established a three-tiered
approach to planning its research efforts, beginning with a strategic plan for ORD for the
next five to ten years. This plan focuses research into six areas including the following:
• Research that addresses questions related to defining or ameliorating high-risk
areas
4-29
-------
Table 4-5. Distribution of Laboratory Functions by Environmental Problem
Environmental
Problem
Air
Radiation
Soils /Terrestrial
Marine/Esluarine
Waler
Fresh Waler/
Ground Waler
Drinking Waler
Solid/ Hazardous
Waste
Multimedia
Human Health
Risk Assessment
Pesticides
Math Modeling
Scientific and Technological Functions
Analytical
Support
ESO
NVFEL/AA
EMS LAV
NAHEL/MON
ORIAAV
ESO
ESO
RRELCIN
ESO
ESO
ESO
HREL/CIN
ESO
ESO
ESO
RREl/CIN
ACUBEL
ECl/BSl
ESO
Applicalion-
Direded
Research
AEERL/mP
AREAL/RTP
ERL/ATH
ERL/COR
ECAO/RTP
HERL/RTP
EMS LAV
NAHEL/MON
EMS LAV
EHL/ADA
' ERL/ATH
ERUCOH
EHL/NAR
RREL/CIN
ERL/ATH
ERL/GB
RHEL/CIN
ERL/ADA
ERL/ATH
EHL/COR
EHL/OUL
EMSL/CIN
RHEL/CIN
TSD/CIN
AEEHL/RTP
AHEAL/flTP
RRELCIN
EMSL/CIN
EMS LAV
ERL/ATH
Efll/ATH
ERL/COH
ECAO/CIN
HEHL/OTP
HHAG/OC
ECAO/CIN
EAG/DC
ERL/ATH
AREAL/RTP
ERUDUL/ULR3
ERL/ATH
ERUCOR
Development
AEERL/RTP
AR6AURTP
EMB^TP
ESO
NVFEL/AA
EMSL/LV
ERL/AOA
EHL/ADA
ERL/ATH
HREL/C1N
ESO
ERL/GB
EHL/NAHH
RREL/CIN
EHL/ADA
eso
EMSL/CIN
HREL/CIN
TSD/CIN
AEERURTP
RHELXIN
AREAL/WTP
eso
ESO
HHAG/DC
ECAO/CIN
ESO
Emergency/
Episode
Response
ESO
NAREL/MOM
OHIAA.V
ESO
ESO
ESO
TSD/CIN
ESO
ESO
ESO
ESO
ESO
Enforcement/
Compliance
NEC/DEN
ESO
NVFEL/AA
NErC/OEN
ESO
NEC/DEN
ESO
NEC/DEN
ESO
NEC/DEN
ESO
NEC/OEN
ESO
NEC/DEN
ESO
NEIC/OEN
ESO
NEC/DEN
ESO
NEC/DEN
ESO
Fundamental
Research
AREAL/HTP
AEERL/HTP
ERL/COH
ERL/ADA
EHL/ATH
ERL/COH
RREL/CIN
ERL/GB
ERLfflARR
ERL/ADA
ERL/ATH
ERL/COR
ERIJDJL
RHEL/CIN
AEERL/HTP
HREL
AREAURTP
EHUCOH
EHUGB
ECAO/CIN
HEHL/RTP
HHAO/OC
ECAO/CIN
ECAO/RTP
EAO/DC
ERL/ATH
Monitoring
AREAL/HTP
EMBmTP
ESO
EMS LAV
ESO
NAREL/MON
EMS LAV
ESO
ERL/GB
ESO
ESO
TSD/CIN
ESO
EMSL/LV
ESO
ESO
ESO
EAO/DC
ESO
Quality
Oversight
AREAL/RTP
EMB/RTP
ESO
EMS LAV
NAREL/MON
ESO
ESO
ESO
EMSL/CIN
TSD/CIN
ESO
EMSL/LV
RREl/CIN
ORIAyLV
ESO
ESO
HERL/RTP
EAG/DC
ECL/BSL
ACL/BEL
State/
Local
Oversight
ESO
NVFEL/AA
NAREL/MON
ESO
ESO
ESO
ESO
ESO
ESO
ESO
Technical
Asst «
Service
AEEHL/HTP
ECAO/RTP
EMB/RTP
ESO
NVFEL/AA
EMS LAV
NAREL/MON
ORIAAV
ERL/ADA
RREL/CIN
ESO
ERL/NARR
ESO
ERL/ADA
ERL/ATH
ESO
EMSL/CIN
RREL/CIN
TSD/CIN
AEERL/R7P
AHEAL/HTPRHHEL/
CIN
EHL/AOA
ESO
ECAO/CIN
HERL/HTP
HHAG/DC
ESO
ECAO/CIH
EAG/DC
ECL/BSL
ACUBEL
ERL/ATH
Technology
Transfef
AEEHL/mP
EMB/RTP
ESO
ORIAAV
ESO
ERUGB
ESO
ERL/ADA
ERL/ATH
ESO
EMSL/CIN
RREL/CIN
TSO/CIN
ESO
RHEL/CIN
ORIAA.V
ESO
ERL/AOA
ESO
HERl/RTP
HHAG/OC
ESO
ESO
ESO
EHL/ATH
-------
• Improving human health risk assessment capabilities
• Understanding human-induced risk to complex ecological systems
• Innovative risk reduction and pollution prevention
• Technology transfer
• Maintaining and enhancing scientific excellence
Goals are established in collaboration and consultation with EPA program offices, the
SAB and, in some cases, other federal agencies.
The second stage of the process involves development of three- to five-year research
plans for each of the goals. These plans contain the 36 issues that give rise to the phrase
"issue-based planning" used to describe the entire ORD research planning process. Each
of the 36 issues is assigned an issue planner who, supported by an issue-planning group
consisting of ORD laboratory scientists, ORD headquarters staff, and program office and
regional representatives, is responsible for managing the research plan for a particular
issue.
In the final step, the issues are developed into projects and tasks to be implemented at
the laboratories. Each of the ORD laboratories prepares a Laboratory Implementation Plan
detailing the activities at that laboratory. Preliminary results of this process can be seen in
Table 4-6, which shows the distribution of work conducted for each of the issues among
the various ORD laboratories. ORD laboratories submitted their first Laboratory
Implementation Plans in early 1994. These draft plans are now under review and, once
finalized, they will be used to integrate individual laboratory tasks and projects into the
larger ORD-wide issue research plans.
With few exceptions, each ORD laboratory is participating in 6 to 14 issues, and each
issue is distributed over 3 to 8 laboratories. While it may be necessary to partition the
issues among the laboratories to encompass the full range of expertise needed, it places
management burdens on the laboratory director to control the resources appropriately and
upon the issue planner to integrate the results. Further examination of the situation could
indicate how laboratories might be consolidated or how the issues could be better defined.
4-31
-------
TABLE4_6.XLS
Table 4-6. FTE From 1994 Laboratory Implementation Plans
Laboratory
ORD/AEERL/RTP
ORD/AREAL/RTP
ORD/EAG/DC
ORD/ECAO/CIN
ORD/ECAO/RTP
ORD/EMSL/CIN
ORD/EMSL/LV
ORD/ERL/ADA
ORD/ERL/ATH
ORD/ERL/COR
ORD/ERL/DUL
ORD/ERL7GB
ORD/ERL/NARR
ORD/HERL/RTP
ORD/HHAG/DC
ORD/RREL/CIN
Total
Coastal and Marine
0.5
21.1
21.6
Large Lakes and Rivers
0.5
8.3
8.8
Wetlands
4.0
2.6
1.1
1.1
8.8
Contaminated Sediments
0.2
2.5
10.9
15.6
*
29.2
Aquatic Ecocriteria
0.1
2.0
*
3.6
16.2
14.0
4.0
39.9
Nonpoint Sources
0.4
1.5
8.0
0.5
1.5
11.9
Ecorisk Assessment
19.0
7.0
5.2
11.4
5.9
3.3
51.8
Habitat Biodiversity
0.6
1.0
1.6
Biotechnology
0.2
5.0
2.0
10.4
5.3
0.1
23.0
m
"D
9.7
4.8
11.2
6.3
2.9
2.6
4.5
42.0
CD
o
cr
K.
Q
CD
CD
8.8
4.0
4.6
7.5
11.4
1.0
0.5
1.0
38.8
Stratospheric Ozone
8.4
2.1
0.5
3.0
0.2
14.2
Acid Deposition
2.9
6.8
2.0
11.7
Air Toxics
8.7
16.4
0.2
1.3
4.2
0.5
11.5
42.8
Criteria Air Pollutants
13.0
35.5
3.0
11.0
20.1
82.6
Motor Vehicles
12.5
1.0
2.6
16.1
Indoor Air
10.8
8.3
0.2
4.0
3.7
0.3
27.3
4^
to
Notes: 1. Two Issues, Infrastructure and Cross Program, were not Included in the table.
2. (*) indicates that no FTE were allocated, but that the lab did plan for dollar expenditures.
-------
TABLE4_6.XLS
Table 4-6. FTE From 1994 Laboratory Implementation Plans (Concluded)
Laboratory
ORD/AEERL7RTP
ORD/AREAL/RTP
ORD/EAG/DC
ORD/ECAO/CIN
ORD/ECAO/RTP
ORD/EMSL7CIN
ORD/EMSL/LV
ORD/ERL7ADA
ORD/ERUATH
ORD/ERLyCOR
ORD/ERUDUL
ORD/ERUGB
ORD/ERL7NARR
ORD/HERURTP
ORD/HHAG/DC
ORD/RREL/CIN
Total
D
3.
nking Water Pollutai
13
to"
4.6
38.6
*
14.4
38.8
96.4
Groundwater
7.0
39.7
8.5
3.0
58.2
S
5
2.6
9.7
12.3
Hazardous Waste
1.3
1.1
1.0
7.6
3.2
11.9
26.6
52.7
Sludge /WW
8.4
8.8
17.2
Surface Cleanup
2.5
4.4
20.2
36.6
63.7
Bioremediatjon
0.5
7.0
5.9
*•
14.1
27.5
Heavy Metals
4.3
0.4
0.6
6.0
0.5
1.7
3.0
16.5
Human Exposure
10.4
1.1
3.0
6.9
*
*
1.0
22.4
Health Effects
11.6
23.4
1.7
36.7
3)
w'
k Assessment Meth
0
Q.
9.2
11.34
0.8
1.0
10.8
33.1
New Chemicals
0.1
0.1
6.3
5.2
26.8
1.0
39.5
Pollution Prevention
3.6
*
1.0
14.2
18.8
—
inovative Technolog
5.9
4.0
9.9
m
^
ivironmental Educati
o
0.0
rechnology Transfei
0.5
*
0.5
Grants /Centers
0.0
OJ
Notes: 1. Two issues, Infrastructure and Cross Program, were not included in the table.
2. (*) Indicates that no FTE were allocated, but that the lab did plan for dollar expenditures.
-------
4.3.2 Program Office Laboratories and ESOs
Planning for activities at the program office laboratories and for the ESOs is built
upon the closer organizational alignment between these units and their primary customers.
Program office laboratory activities are defined and priorities are set by the Assistant
Administrator for the program offices through coordination within the specific programs
and are based upon the recommendations of program-specific research committees. Core
environmental service activities are determined through an annual planning process
involving the regional program offices and the ESOs within each region. The nature of
these discussions varies from region to region, but some regions go so far as to negotiate
formal agreements between environmental services and individual regional program
offices.
4.4 FINANCES
Table 4-7 shows EPA's FY93 and FY94 appropriations, as passed by the U.S.
Congress. For FY93, the total for ten appropriations was about $6.9 billion. However,
about $2.5 billion of the total was appropriated for water infrastructure/state revolving
funds, which are primarily grants to the states for water and wastewater projects. A better
figure for EPA's actual operating budget is about $4.3 billion, which is the total
appropriations less the water revolving funds. The R&D FY93 appropriation, which is
ORD's primary source of funding, represents about 7.5 percent of the FY93 total
appropriations less revolving funds. Funding for laboratory operations of all types is
derived from eight of the ten appropriations, including R&D (ORD only); program and
research operations (PRO) (personnel compensation and benefits and travel expenses);
abatement, control, and compliance (AC&C); buildings and facilities (B&F); hazardous
substance Superfund (SF); leaking underground storage tank trust fund (LUST) and oil
spill response.
Table 4-8 gives an overview of the total FY93 financial expenditures for each
laboratory type. The individual laboratory expenditures data for FY91, FY92, and FY93
are provided in Appendix A, Table 2. ORD headquarters expenditures are not included in
Table 4-8 unless reported by an ORD laboratory. For ORD, the interagency agreements
(funds-in) and other funds-in (FITA and IGA) are included in the extramural subtotal as
well as being shown separately. It should be noted that funds for analytical services in
support of Superfund are not included in the regional expenditures listed in Table 4-8.
Under the program offices, all of the expenditures of the Office of Mobile Sources are
included, not just the laboratory portion. For the program office laboratories, the
interagency agreements and other funds-in are not included in the extramural subtotal and
therefore have been included in the total.
4-34
-------
(APPROPR.XLW)APPROPR.XLS
Table 4-7. EPA Appropriations
Appropriation
Research and Development (R&D)
Abatement, Control, and Compliance (AC&C)
Abatement, Control, and Compliance Loan Program Account
Program and Research Operations (PRO)
Office of Inspector General (3)
Buildings and Facilities (B&F)
Hazardous Substance Superfund (SF)
Leaking Underground Storage Tank Trust Fund (LUST)
Oil Spill Response
Water Infrastructure/State Revolving Funds
Total:
Total w/o Water Infrastructure/State Revolving Funds:
FY1993
(1)
$323,000,000
$1,318,965,000
$31,225,000
$823,607,000
$42,799,000
$134,300,000
$1,573,528,000
$75,000,000
$20,000,000
$2,550,000,000
$6,876,044,000
$4,326,044,000
FY1994
(2)
$338,701,000
$1,352,535,000
$850,625,000
$44,595,000
$18,000,000
$1,465,853,000
$75,379,000
$21 ,239,000
$2,477,000,000
$6,643,927,000
$4,166,927,000
Notes:
(1) Source: H.R. 5679, Departments of Veterans Affairs and Housing
and Urban Development, and Independent Agencies Appropriations
Act, 1993 (Pub. L. 102-389, approved 10/06/92) [H.Rept. 102-902]
(2) Source: H.R. 2491, Departments of Veterans Affairs and Housing
and Urban Development, and Independent Agencies Appropriations
Act, 1994 (Pub. L 103-124, approved 10/28/93) [H.Rept. 103-273]
(3) A portion of OIG funds are derived from Superfund and LUST
trust funds and these amounts are not counted in the total.
4-35
-------
TABLE4-7.XLS
Table 4-8. EPA FY93 Laboratory Financial Data Summary
Category
Personnel Costs
Travel Expenses
Facility Maintenance and Operations
Facility Repair and Improvement
Administrative Equipment
Scientific Instrumentation
Administrative Services
Misc. and Other Intramural
Operating Costs
Intramural Subtotal:
Extramural Contracts
Grants
Cooperative Agreements
Interagency Agreements (Funds-Out)
Extramural Subtotal:
Interagency Agreements (Funds-ln) (2)
Other Funds-ln (FTTA and IGA) (2)
Funds-ln Subtotal:
Total:
Percent of EPA Total:
ORD Program Office ESO
(1)
$97,486,564 $29,365,525 $34,504,834
$3,936,793 $704,562 $1 ,547,707
$7,097,964 $2,622,088 $2,137,710
$1,051,027 $114,927 $67,414
$6,160,124 $323,060 $319,564
$7,756,766 $1,288,748 $6,858,983
$8,711,780 $2,089,298 $1,530,508
$5,813,117 $1,296,640
$138,014,135 $37,804,848 $46,966,720
$120,562,127 $22,899,482 $1,925,542
$13,131,947 $2,465,040
$84,997,593 $655,000
$35,809,773 $924,105 $513,986
$254,501,440 $26,943,627 $2,439,528
($17,576,359) $960,500
($500,551)
($18,076,910) $960,500 $0
$392,515,575 $65,708,975 $49,406,248
77% 1 3% 1 0%
EPA Total
$161,356,923
$6,189,062
$1 1 ,857,762
$1,233,368
$6,802,748
$15,904,497
$12,331,586
$7,109,757
$222,785,703
$145,387,151
$15,596,987
$85,652,593
$37,247,864
$283,884,595
$18,536,859
$500,551
$19,037,410
$507,630,798
Sources: ORD/ORPM (ORD data) and Laboratory/ESO Directors (Program Offices and ESOs)
Notes:
(1) Data were not available for the program office laboratory in Bay City, Ml.
(2) ORD Funds-ln are included in Intramural and Extramural expenditures.
4-36
-------
Of the three laboratory types, ORD represents the largest operation by a substantial
margin, accounting for about 77 percent of EPA's laboratory expenditures. The program
office and Environmental Services laboratories are roughly equal in terms of expenditures
at 13 percent and 10 percent, respectively.
Figure 4-9 shows the intramural and extramural expenditures of the ORD laboratories,
which are highly leveraged with regard to extramural contracts, grants, and cooperative
and interagency agreements. In 14 of ORD's laboratories, 50 percent or more of the
expenditures are extramural. Overall, in FY93, ORD spent about 1.8 times more on
extramural contracts and agreements than it did on intramural operations.
Figure 4-10 shows the intramural and extramural expenditures of the program office
laboratories and ESOs (core functions of laboratory services, QA/QC, and field
monitoring). NVFEL has the largest total expenditure, of which 45 percent is extramural.
The extramural expenditures of ESOs appear to be low or nonexistent, but additional
extramural support may be obtained through the Contract Laboratory Program, which is
not included here.
In addition to direct expenditures made by the laboratories, OARM expends funds on
the buildings and facilities of the laboratories; these are not included in the laboratories'
budgets. Table 4-9 details such expenditures made by OARM in FY93 for construction,
repair, improvement, alteration, and purchase of fixed equipment, buildings, and facilities
(B&F); rents at certain facilities; and utilities costs at certain facilities. In total, these
expenditures amounted to about $25 million for FY93, which is approximately equal to
5 percent of total laboratory expenditures. OARM B&F expenditures on a laboratory or
group of laboratories usually greatly exceed repair and improvement (R&I) expenditures
made by the individual laboratories (see Table 4-11 F&E Expenditures Summary).
In Table 4-10, EPA's FY93 laboratory expenditures are compared to EPA's FY93
appropriations. In this table, "funds-in" have been subtracted from the laboratory
expenditures because they represent funds from outside of the Agency. Also, OARM B&F
expenditures have been added to the laboratory expenditures because they are funds
expended by the Agency to maintain and operate the laboratory system, even though they
do not appear in individual laboratory budgets. At the bottom of the table, FY93
laboratory total expenditures are shown as a percentage of the FY93 appropriations, both
with and without state revolving funds and by laboratory category. Overall, EPA spent
approximately 12 percent of its FY93 operating budget (appropriations less revolving
funds) on its laboratory system and operations.
4-37
-------
FIG4-9.XLS Charts
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$50,000 -
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H Intramural Subtotal
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Source: ORPM/ORD
Laboratory
Figure 4-9. FY93 EPA Laboratory Expenditures
ORD Laboratories
4-38
-------
FIG4-10.XLS Chart 9
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$60,000 -
$50,000 -
o
$40,000 -
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$30,000 -
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D Extramural Subtotal
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Laboratory
Figure 4-10. FY93 EPA Laboratory Expenditures
Program Office Laboratories and Environmental Services Organizations
4-39
-------
(APPROPR.XLW)OARM Expenditures
Table 4-9. FY93 OARM Expenditures
On Behalf of Laboratories (B&F, Rents, and Utilities)
Laboratory Location
ORD
RTF (w/o OAQPS)
Las Vegas
Cincinnati
Gulf Breeze
Athens (ERL)
Duluth
Ada
Covallis
Narragansett
Vint Hill
Grosse lie
ORD Subtotal:
Program Office
RTF (OAQPS/EMB)
Denver
Bay St. Louis
Beltsville
Program Office Subtotal:
ISO
Lexington
Edison (R2 ESO)
Annapolis
Wheeling (R3 ESO)
Athens
Westlake (R5 ESO)
Chicago (lab only)
Houston
Kansas City
Denver
San Francisco
Manchester
ESO Subtotal:
Nationwide Projects:
EPA Total:
B&F
$1,023,450
$95,764
$1,311,489
$183,033
$179,064
$93,743
$1,701,819
$49,465
$390,000
$2,230
$80,000
$5,110,057
Rent Utilities
$6,333,059
$879,786 $430,000
$138,620
$7,351,465 $430,000
$91,631
$1,092,703
$243,000
$232,604
$1,568,307
$4,550
$467,281
$13,266
$546,812
$694,021
$280,159
$2,006,089
$1,065,500
$1,251,458
$223,741
$110,115
$378,065
$1,268,607
$880,177 $325,000
$589,784
$178,513
$180,511
$6,126,471 $325,000
$2,336,000
$9,452,146
$15,046,243 $755,000
Total
$7,356,509
$1,405,550
$1,311,489
$183,033
$179,064
$93,743
$1,701,819
$49,465
$390,000
$140,850
$80,000
$12,891,522
$91,631
$1 ,092,703
$243,000
$232,604
$1,568,307
$1,070,050
$467,281
$1 ,264,724
$223,741
$656,927
$378,065
$1 ,268,607
$1,205,177
$589,784
$872,534
$180,511
$280,159
$8,457,560
$2,336,000
$25,253,389
Source: OARM/FMSD
4-40
-------
[APPROPR.XLW]table 4-10
Table 4-10. EPA FY93 Laboratory Expenditures as a Percentage of EPA FY93 Appropriations
Category
Laboratory Expenditures (less "Funds-ln"):
OARM Expenditures On Behalf of
Laboratories (B&F and Rents):
Total EPA Expenditures on Laboratories:
EPA Appropriations (less Revolving Funds):
Total EPA Appropriations
Laboratory Expenditures (including OARM Expenditures)
as Percentage of EPA Appropriations (less Revolving Funds)
Laboratory Expenditures (including OARM Expenditures)
as Percentage of Total EPA Appropriations:
ORD
$374,438,665
$12,891,522
$387,330,187
Program Office
$64,748,475
$1,568,307
$66,316,782
ESO
$49,406,248
$8,457,560
$57,863,808
9%
6%
2%
1%
1%
1%
EPA Total
$491,515,490
$25,253,389
$516,768,879
$4,326,044,000
$6,876,044,000
12%
8%
Sources: See Tables 4-6, 4-7, and 4-8
-------
4.5 FACILITIES AND EQUIPMENT
Collectively, ORD's expenditures for facilities maintenance and operations, and for
administrative equipment and scientific instrumentation were $22,065,881 in FY 93
(Table 4-8). The combination of the four categories are referred to hereafter as facilities
and equipment (F&E) costs. These costs for ORD were 16 percent of all intramural
expenditures by the laboratories and 2.8 percent of their total expenditures (intramural,
extramural, interagency, and other funds). A three-year profile of these costs for each of
the laboratories is presented in Appendix A and a summary of the total F&E costs in
descending order by laboratory is presented in Table 4-11. Average annual expenditures
per unit work year are shown in Figure 4-11. The wide variation within the ORD
laboratories and the ESOs that occur if only FTEs are included tend to disappear, as
would be expected, when the total work force is included.
On a three-year basis, F&E costs ranged from 2 percent (Releases Control Branch
[RGB] and Human Health Assessment Group [HHAG]) to 40 percent (Gulf Breeze) of
intramural expenditures, and from 1 percent (RGB, HHAG, Environmental Assessment
Group [EAG], and Environmental Photographic Investigation Center [EPIC]) to 19 percent
(Gulf Breeze) of the total costs over a three-year period as shown in Table 4-11. The
largest costs for the total of F&E over the past three years have been incurred at Gulf
Breeze and Health Effects Research Laboratory (HERL), followed by Corvallis,
Atmospheric Research and Exposure Assessment Laboratory (AREAL), Environmental
Monitoring Systems Laboratory/Las Vegas (EMSL/LV), and Narragansett. Based on
facilities and maintenance costs alone, the largest costs have been incurred at
Narragansett, Corvallis, Athens, and Gulf Breeze. Even so, the condition of these facilities
reported in Table 4-12 is only medium; they have not been upgraded to a good condition.
The largest investments in scientific instrumentation and administrative equipment have
been made at HERL, AREAL, EMSL/LV, and Corvallis, followed by Risk Reduction
Engineering Laboratory (RREL), Gulf Breeze, EMSL/Cincinnati (GIN) and Air and
Energy Engineering Research Laboratory (AEERL).
In the program office laboratories, $4,348,823 was expended in FY93 for the total of
F&E categories. These costs represented 11.5 percent of the intramural expenditures and
6.6 percent of the total of the intramural and extramural expenditures. In both cases, the
F&E costs aggregated across the program office laboratories is about the same portion of
their total expenditures as is the case in ORD's laboratories. A three-year profile of these
costs for each of the program office laboratories is presented in Appendix A and a
summary of the total F&E costs by laboratory is presented in Table 4-11.
On a three-year basis, F&E costs ranged from 1 percent (Office of Air Quality
Planning and Standards [OAQPS]) to 28 percent (Environmental Chemistry Laboratory
4-42
-------
Table 4-11. Facilities and Equipment (F&E) Expenditures Summary
(Ordered By Total F&E Expenditures)
[TABL4-11 .XLWTTab te 4-11
Laboratory
ORD/ERL/GB
ORD/HERURTP
ORD/ERUCOR
ORD/AREAL/RTP
ORO/EMSLAV
ORD/ERL/NARR
ORD/ERL/ADA
ORD/RREL/CIN
ORD/ERL/ATH
ORD/AEERURTP
ORD/ERUDUL
ORD/EMSUCIN
ORD/ERL/NARR/PEB
ORD/ERUDUL/LLRS
ORD/ECAO/CIN
ORD/ECAO/RTP
ORD/HHAQ/DC
ORD/EMSL/tV/EPIC
OROmREL/RCB/EDIS
ORD/EAG/DC
ORD Subtotal:
Scientific
OARM Instrumentallon
Facility and Buildings and Facility and
Maintenance Facilities Repair and Administrative
Operations (B&F) Improvement Equipment
Expenditures Expenditures Expenditures Expenditures
(3 Years) (3 Years) (3 Years) (3 Years)
0)(2) (3) (2) (2)
$2,407,581 $2,970,130 $176,078 $2,760,538
$575,814 $873,283 $130,190 $6,643,313
$3,797,087 $343,519 $211,504 $3,490,211
$349,956 $958,695 $184,325 $4,923,304
$738,428 $202,651 $873,690 $4,273,685
$4,226,436 $426,302 $8,507 $1,387,078
$1,618,189 $1,959,393 $29,976 $1,802,779
$726,031 $1,646,370 $33,136 $2,893,229
$2,469,502 $290,978 $121,087 $1,918,292
$211,452 $986,715 $421,070 $2,269,372
$1,842,338 $475,252 $93,163 $1,120,788
$330,120 $516,327 $2,886 $2,589,746
$785,246 $175,179 $0 $234,000
$542,608 $169,190 $45,295 $260,661
$56,814 $82.398 $71,571 $215,702
$30,503 $0 $0 $318,765
$27,106 $0 $0 $133,866
$14,945 $59,832 $0 $75,665
$0 $51,401 $0 $92,500
$10,118 $0 $0 $108,518
$20,760,274 $12,187,615 $2,402,480 $37,512,412
Total
Facilities and
Equipment
(F&E)
Expenditures
(3 Years)
$8,314,327
$8,222,600
$7,842,321
$6,416,280
$6,088,454
$6,048,323
$5,410,339
$5,298,766
$4,799,859
$3,888,609
$3,531,541
$3,439,079
$1,194,425
$1,017,954
$426,485
$349,268
$160,972
$150,642
$143,901
$118,636
$72,662,781
Total
Total Intramural +
Intramural + Extramural +
B&F(I/BF) B&F(I/E/BF)
Expenditures Expenditures
(3 Years) (3 Years)
(2) (3) (2) (3)
$20,770,515 $43,973,111
$55,531,812 $149,235,750
$25,135,485 $81,031,659
$42,295,016 $163,115,611
$42,497,047 $112,700,368
$18,360,569 $35,203,975
$18,317,830 $42,107,703
$47,957,864 $175,666,501
$20,668,608 $46,390.403
$24,575,086 $96,063,678
$20,270,991 $40,275,581
$26,537,932 $49,793,597
$5,300,969 $8,072,369
$2,554,281 $9,546,677
$7,477,741 $14,867,160
$6,955,437 $16,857,409
$8,053,872 $13,297,021
$1.341,092 $10,603,617
$5,865,601 $21,738,801
$3,533,709 $8,292,650
$404.001,477 $1,138,833,641
F&E F&E
Expenditures Expenditures
as as
Percent of Percent ol
Total I/BF Tola! I/E/BF
Expenditures Expenditures
40% 19%
15% 6%
31% 10%
15% 4%
14% 5%
33% 17%
30% 13%
11% 3%
23% 10%
16% 4%
17% 9%
13% 7%
23% 15%
40% 11%
6% 3%
5% 2%
2% 1%
11% 1%
2% 1%
3% 1%
18% 6%
Total
On-Slte
Workforce
Number (Intramural
of and
FTEs Extramural;
(4) (4) (5)
58 189
227 483
64 265
166 346
151 268
54 170
56 129
203 304
74 132
102 178
80 149
119 226
21 42
7 30
39 52
32 45
31 36
10 24
28 36
16 19
1535 3123
Average Average
Annual F&E Annual F&E
Expenditures Expenditures
Per Per
Unit Work- Unit Work-
Year Year
(EPA FTE (Total
Only) Workforce)
$47,866 $14,640
$12,101 $5,674
$40,845 $9,883
$12,915 $6,185
$13,485 $7,564
$37,405 $11,866
$32,204 $14,035
$8,701 $5,812
$21,534 $12,084
$12,770 $7,262
$14,642 $7,906
$9,649 $5,074
$19,234 $9,401
$49,900 $11,199
$3,673 $2,739
$3,684 $2,564
$1,725 $1,466
$5,021 $2,137
$1,725 $1,340
$2,519 $2,115
$15,825 $7,778
Note
(1) 3 Years: FY91 - FY93
(2) Source: Appendix A, Table 2. (each laboratory)
(3) Source: Appendix A, Table 3. (each laboratory) (OARrWFMSD)
(4) Source: ORD/ORPM (ORD only), Laboratory Director, Environmental Services Director, or Branch Chief (as appropriate)
(5) Source: Appendix A, Table 7. (each laboratory) (Workforce 94)
-------
Table 4-11. Facilities and Equipment (F&E) Expenditures Summary (Concluded)
(Ordered By Total F&E Expenditures)
[TABL4-11.XlWTrable4-11
Laboratory
OAR/OMS/NVFEL/AA
OE/NEIC/DEN
OAR/NAREUMONT
OPP/ECUBSL
OPP/ACUBELTS
OAR/ORIA/LV
OGWOW/TSD/CIN
OAR/OAQPS/EMB/RTP
Program Office Sublotil:
R02/ESD/EDIS
R10/ESD/SEA
R04/ESD/ATH
R07/ESD/KAN
R05/ESD/CHI
R06/ESD/HOU
R01/NERL/LEX
R03/CRL/ANN
R08/ESD/DEN
R09/ESB/RICH
ESO Subtotal:
EPA Total:
Scientific
Instrumentation
Facility and OARM Facility Repair and
Malmenance Buildings and and Administrative
Operations Facilities (B&F) Improvement Equipment
Expenditures Expendrtures Expenditures Expenditures
(3 Yean) (3 Years) (3 Years) (3 Years)
(t)(2) (3) (2) (2)
$2,938,000 $143,045 $325,000 $2,664,300
$1,084,574 $552,667 $342,515 $2,613,659
$568,400 $18,672 $87,200 $1,040,500
$701,077 $0 $0 $544,084
$699,782 $6,802 $0 $221,918
$110,300 $0 $1,000 $289,700
$43,324 $228,435 $0 $50,140
$7,000 $0 $1,000 $32,000
$6,152,457 $949,621 $756,715 $7,456,301
$4,502,202 $748,545 $0 $3,119,125
$1,147,300 $919,071 $22,000 $2,311,200
$140,764 $546,812 $50,000 $2,886,626
$22,000 $369,076 $0 $2,908,128
$267,149 $9.475 $30,277 $2,543,435
$0 $43,767 $9,500 $2,554,759
$0 $480,396 $196,044 $1,818,505
$116,658 $50,522 $4,382 $2,169,314
$51,900 $943,286 $35,700 $1,015,000
$0 $7,555 $0 $1,066,600
$6,247,973 $4,118,507 $347,903 $22,392,692
$33,160,704 $17,255,743 $3,507,098 $67,361,405
Total
Facilities and
Equpment
(F&E)
Expenditures
(3 Years)
$6,070,345
$4,593,415
$1,714,772
$1,245,161
$928,502
$401,000
$321,899
$40,000
$15,315,094
$8,369,872
$4,399,571
$3,624,202
$3,299,206
$2,850,336
$2,608,026
$2,494,945
$2,340,876
$2,045,886
$1,074,155
$33,107,075
$121,284,950
Total
Total Intramural +
Intramural + Extramural + B&F
B&F (I/BF) (I/E/BF)
Expenditures Expendrtures
(3 Years) (3 Years)
(2) (3) (2) (3)
$53,772,345 $105,122,345
$26,745,724 $50,043,123
$8,522,472 $10,957,772
$4,447,380 $4.967,360
$4,162.587 $4,262,587
$3,735,600 $4,735,000
$4,342,475 $7,366,001
$4,569,900 $17,785,200
$ 1 1 0,298,483 $205,239,408
$25,341,400 $26,422,400
$18,557,421 $18,820,171
$21,230,889 $21,230,689
$18.369,113 $23,121,302
$11,641,212 $11,653,212
$14,389,009 $14,429,109
$11,240,291 $11,479,956
$8,293,255 $9,105,832
$6,020,236 $6,031,236
$4,648,553 $5,386,453
$139,731,379 $147,680,560
$654,031,339 $1,491,753,609
FIE
Expendrtures F&E
as Expenditures
Percent ol as Percent ol
Total I/BF Total I/E/BF
Expenditures Expendrtures
11% 6%
17% 9%
20% 16%
28% 25%
22% 22%
11% 8%
7% 4%
1% 0%
14% 7%
33% 32%
24% 23%
17% 17%
18% 14%
24% 24%
18% 18%
22% 22%
28% 26%
34% 34%
23% 20%
24% 22%
19% 8%
Total
On-Srte
Workforce
(Intramural
Number and
of FTEs Extramural)
<4) W (S)
277 365
120 173
39 59
17 19
17 17
16 26
23 32
25 25
534 714
86 93
81 140
113 146
82 120
82 144
36 67
51 61
63 131
25 42
21 48
639 992
2708 4828
Average Average
Annual F&E Annual F»E
Expendrtures Expenditures
Pet Per
Unit Work- Unit Work-
Year Year
(EPAFTE (Total
Only) Workforce)
$7,305 $5,550
$12.728 $8,861
$14,619 $9,771
$24,415 $22,315
$18,206 $16,206
$8,624 $5,201
$4,665 $3,396
$533 $529
$9,562 $7,150
$32,631 $30,000
$18,173 $10,498
$10,729 $8,297
$13,411 $9,164
$11,559 $6,589
$24,148 $12,975
$16,307 $13.634
$12,386 $5,960
$26,849 $16,084
$17,050 $7,459
$17,259 $11,127
$14,929 $8,373
Notes:
(1) 3 Years: FY91 - FY93
(2) Source: Appendix A, Table 2. (each laboratory)
(3) Source: Appendix A, Table 3. (each laboratory) (OARM/FMSD)
(4) Source: ORD/ORPM (ORD only). Laboratory Director. Environmental Services Director, or Branch Chief (as appropriate)
(5) Source: Appendx A. Table 7. (each laboratory) (WorWorce '94)
-------
[TABL4-11.XLW]Figure4-11 Chart 1
5/27/94
£
$50,000 -i
* $45,000
(D
S $40,000 -
5
| $35,000 -
Q.
$10,000
2
4)
< $5,000
$0
Source: See Table 4-11
D Per Unit FTE
H Per Unit Total Work-Year (Intramural and Extramural)
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Laboratory
Figure 4-11. Average Annual Facilities and Equipment Expenditures per Unit Work-Year (FY93)
-------
TAB1_4-12.XLS - 5/27/94
Table 4-12. Laboratory Space Summary
Laboratory
QBB
ORD/AEERL/RTP
ORD/AREAL/RTP
ORD/EAG/DC
ORD/ECAO/CIN
ORD/ECAO/RTP
ORD/EMSL/CIN
ORD/EMSL/LV
ORD/EMSL/LV/EPIC
ORD/ERUADA
ORD/ERL/ATH
ORD/ERUCOR
ORD/ERL/DUL
ORD/ERL/DUL/LLRS
ORD/ERL/GB
ORD/ERL/NARR
ORD/ERL/NARR/PEB
ORD/HERL/RTP
ORD/HHAG/DC
ORD/RREL/CIN
ORD\RREL\RCB\EDIS
ORD Totals:
Location
RTP NC
RTP NC
Washington DC
Cincinnati OH
RTP NC
Cincinnati OH
Las Vegas NV
Warrenlon VA
Ada OK
Athens GA
Corvalis OR
Dululh MN
Grosse lie Ml
Gull Breeze FL
Narragansett Rl
Newport OR
RTP NC
Washington DC
Cincinnati OH
Edison NJ
Approx.
Total
On-slte
Workforce
(D
178
346
19
52
45
226
268
24
129
132
265
149
30
189
170
42
483
36
304
36
3123
Number of Buildings
1
5
1
1
1
3
8
1
5
11
17
10
5
53
9
3
4
5
1
144
Space Summary (net sf)
i
f
21,610
92,082
1,500
7,610
10,598
18,328
50,000
7,360
23,726
14,168
32,102
14,002
8,511
15,426
17,177
9,500
49,164
3,600
42,077
6,000
444,541
Laboratory
33,853
55,049
1,150
56,989
25,000
4,958
13,449
11,589
29,634
22,696
4,359
28,208
18,696
22,200
65,717
56,707
450,254
Other (2)
22,600
1,146
2,703
12,426
25,000
5,631
14,183
12,642
33,665
11,618
10,865
28,264
20,416
1 1 ,650
60,454
975
13,345
287,583
Total
55,463
169,731
1,500
9,906
13,301
87,743
100,000
17,949
51,358
38,399
95,401
48,316
23,735
71,898
56,289
43,350
175,335
4,575
112,129
6,000
1,182,378
Lease/Own
Status
Status (3)
E-L
E-L
E-O
E-L
E-O
E-L
E-L
E-O
E-O
E-O
E-O
E-O
E-O
E-O
E-O
E-L
E-O
E-O
Lease Expiration
Mar-98
Feb-94
Aug-96
Sep-96
Annually
Mar-98
Costs
3-Year
Buildings and
Annual Le.»Fac|||t|es(B&F)
Expenditures
(FY91 - FY93)
$1,061.143 $986,715
$2,294,701 $958,695
$82,398
$209,496
$516,327
$964,800 $202,651
$138,620 $59,832
$1,959,393
$290,978
$343,519
$475,252
$169,190
$2,970,130
$426,302
$175,179
$6,377,977 $873,283
$1.646,370
$51,401
$11,046,737 $12,187,615
Condition
Oldest Building
1969
1966
1976
1976
1966
1957
1965
1964
1967
1967
1977
1910
1963
1990
1966
1967
1943
Newest Building
1969
1983
1976
1989
1984
1957
1992
1988
1990
1984
1977
1990
1990
1990
1994
1978
1943
General Condition (4)
M
M
G
G
G
M
M
M
M
M
M
P
M
M
G
M
G
P
£
OS
Sources: USEPA/OARM/FMSD and Individual laboratories
Notes:
(1) Based on sum of Intramural FTE and extramural work-years.
(2) Includes storage, shops, loading docks, conference rooms, and other special purpose facilities.
(3) E-L: EPA-leased; E-O: EPA-owned; G-L: GSA-leased for EPA; G-O: GSA-owned/leased to EPA.
(4) OARM/FMSD assessment.
-------
TABL4-12.XLS - 5/27/94
Table 4-12. Laboratory Space Summary (Concluded)
Laboratory
Program QfJIcs
OAR/NAREL/MONT
OAR/OAQPS/EMB/RTP
OAR/OMS/NVFEL/AA
OAR/ORIA/LV
OGWDW/TSD/CIN
OE/NEIC/DEN
OPP/ACL/BELTS
OPP/ECL/BSL
Program Office Totals:
ESQ
R01/NERL/LEX
R02/ESD/EDIS
R03/CRL/ANN
H04/ESD/ATH
R05/ESD/CHI
R06/ESD/HOU
R07/ESD/KAN
R08/ESD/DEN
R09/ESB/RICH
R10/ESD/SEA
ESO Totals:
EPA Totals:
Location
Montgomery AL
RTP NC
Ann Arbor Ml
Las Vegas NV
Cincinnati OH
Denver CO
Bellsville MD
Bay St. Louis MS
Lexington MA
Edison NJ
Annapolis MD
Athens GA
Chicago IL
Houston TX
Kansas City KS
Denver CO
Richmond CA
Manchester WA
Approx.
Total
On-slte
Workforce
(1)
59
25
365
26
32
173
17
19
714
61
93
131
146
144
67
144
42
48
140
1016
4853
Numbw of Buildings
1
1
1
2
1
13
5
4
28
1
1
3
6
3
1
1
5
2
3
26
196
Space Summary (net sf)
8
ff
13,536
3,566
40,867
4,441
3,910
25,194
2,087
1,080
94,685
13,429
34,540
23,201
12,007
42,885
10,554
17,171
5,191
6,999
8,962
174,939
714,165
Laboratory
15,500
1,865
110,377
4,315
4,164
11,439
8,169
8,628
164,477
12,031
21,000
13,986
9,011
22,565
15,948
11,052
10,354
14,163
12,599
142,709
757,440
3
5,825
3,265
2,390
1,800
1,023
28,003
2,103
3,142
47,551
7,094
22,000
15,806
13,000
17,114
3,240
8,103
10,305
12,492
11,592
120,746
455,880
Total
34,863
8,698
153,634
10,556
9,097
64,636
12,379
12,850
306,713
32,554
77,540
52,993
34,018
82,564
29,742
36,326
25,850
33,654
28,353
433,594
1,922,685
Lease/Own
Status
Status (3)
E-O
G-L
E-O
E-L
E-O
G-O
E-L
E-L
LMM Expiration
Apr-94
Sep-96
Annually
Annually
G-L
E-O
G-L
E-O
G-O
E-L
G-L
G-O
E-L
E-O
Dec-95
Apr-95
May- 10
Jul-97
Sep-13
Costs
Annual L*a*a
Cost
$91,631
$1,092,703
$232,604
$243,000
$1,659,938
$1,073,195
$1,251,458
$171,391
$1,646,672
$880,177
$589,764
$178,513
$1,808,760
$7,599,950
$20,306,625
3-Y«ar
Building* and
FacHKIss
-------
[ECLABSL]) of the intramural costs, and from less than 1 percent (OAQPS) to 25 percent
(ECLYBSL) of total costs by laboratory over a three-year period as shown in Table 4-11.
The largest costs for the total of F&E over the past three years have been incurred at
NVFEL and NEIC. Based on facilities and maintenance costs only, the largest costs have
been incurred by NVFEL and NEIC. It should be noted that the condition of NEIC as
reported in Table 4-12 is poor and the condition of NVFEL is medium. The largest
investments in scientific instrumentation and administrative equipment have been made at
NVFEL, NEIC, and National Air and Radiation Environmental Laboratory (NAREL). A
request for additional equipment to permit NVFEL to conduct the testing required by the
CAA Amendments has been made, but it is not yet fully funded.
In the ESOs, $9,383,671 was expended in FY93 for the total of F&E. These costs
were 18.9 percent of the total intramural costs and 9.9 percent of the intramural,
extramural, and interagency agreement funds. A three-year profile of these costs for each
of the laboratories is presented in Appendix A, and a summary of the total F&E costs by
laboratory is presented in Table 4-11.
Viewed on a three-year basis, F&E costs ranged from 17 percent (Region 4) to
34 percent (Region 8) of the intramural costs, and 14 percent (Region 7) to 34 percent
(Region 8) of the total intramural and extramural costs. In both cases, the percentage of
costs is in the same range as that reported for the ORD and program office laboratories.
The largest total F&E costs have been incurred by Regions 2, 10, and 4. Based on
facilities and maintenance costs only, the largest costs have been incurred in Region 2
and 10. In Table 4-12, the condition of Region 2 facilities has been rated as poor and
Region 10 as good. The largest investments in scientific instrumentation and
administrative equipment have been made in Region 2, 7, 4, 6, 5, and 10.
Summaries of scientific equipment purchases with costs in excess of $50,000 per item
are presented in Tables 4-13, 4-14, and 4-15 for ORD, program offices, and ESOs,
respectively. With only a few exceptions, in the ORD laboratories and the program office
laboratories for which there are data, most of the equipment costing more that $50,000 is
less than eight years old. In the ESOs that are reported, two have less than 50 percent of
their equipment that is less than eight years old and one laboratory that is only slightly
above 50 percent. These data also give an indication of the amount of major equipment
investments that must be made each year to keep the laboratories at or near the state of
the art. Investment patterns for FY87 through FY94 can be used for an estimate, if it is
assumed that the useful life of scientific equipment is seven to ten years. For ORD
laboratories, total investments of at least $2 million to $3 million per year are needed in
the $50,000 and above categories. For the limited number of program office laboratories
with data reported, the total is in the $500,000 to $700,000 level. For the ESOs, total
4-48
-------
TAB4-13.XLS
Table 4-13. Equipment Inventory Summary (Purchase Price >$50,000)
ORD Laboratories
PurchaM
Y..r
94
93
92
91
90
89
88
87
Subtotal:
Percent of
Total:
86
85
84
83
82
81
80
79
78
77
76
75
74
73
72
71
70
69
Subtotal:
Percent of
Total:
Total:
ORD/AEERL/RTP
$326,161
$193.891
$179.544
$50.825
$59,770
$104,000
$90,000
$1,004,191
46%
$136,861
$272.003
$55,000
$313,057
$404,004
$1,180,925
54%
$2,185,116
I I
I «
j I §
I > i
\ $ 1
I i
I |
ORD/ERUAOA
ORD/EHL/ATH
(1) (1) (1) $104,970 (2)
$161,547
$737,013
$222,611
$89,540
$722,608
$333,072
$2,266,391 $0
60%
$131,554
$158,260
$149,832
$95,308
$112,200
$191,475
$435,231
$165,000
$92,529
$1,531,389 $0
40%
$3,797.780 $0
$55,909
$264,380
$386.940
$540,614
$58,661
$310,580
$0 $0 $1.617,084
94%
$104,267
$0 SO $104,267
S%
$0 $0 $1.721.351
$437,150
$305,186
$487,943
$220.308
$560,896
$545,713
$165.645
$2,827.813
63%
$64,534
$97,000
$625,434
$119,048
$776,870
$1.682,886
37%
$4.510,699
$60,680
$509,622
$79,026
$215,000
$864,326
62%
$283,684
$148,085
$88,963
$520,732
38%
$1 ,385,060
$109,969
$718,095
$536,353
$624,787
$111,460
$2,100,664
95%
$179,360
$150,000
$50,000
$379.360
15%
$2.480.024
Note: Yearly sums are expressed in purchase year dollars, they have not been inflated to current year dollars.
(1) Laboratory has no equipment with a purchase price greater than $50,000.
(2) Equipment inventory is included in parent laboratory inventory.
4-49
-------
TAB4-13.XLS
Table 4-13. Equipment Inventory Summary (Purchase Price >$50,000)
ORD Laboratories (Concluded)
PurcheM
Y..r
94
93
92
91
90
89
88
87
Subtotal:
Percent of
Total:
86
85
84
83
82
81
80
79
78
77
76
75
74
73
72
71
70
69
Subtotal:
Percent ot
Total:
Total:
i i !
m m I
3) 3) i
8 § I
O C r
•a r- r
;
OHD/ERUGB
ORD/ERL/NARR
(2)
$325,489 $55,420
$110,904
$254,037
$57,819
$100,000 $83,873
$225,000
$88,237
$761 ,393 $539,386
83% 27V.
$409,746
$58.210
$153,500 $607.957
$134,502
$148,574
$60,775
$56,000
$153,500 $1,475,764
77% 73%
$914.893 $2,015.150
$147,793
$380,996
$550,904
$60,507
$113.795
$1,253,995
81%
$236,406
$62.570
$298,976
19%
$1,552.971
$483,525
$139.115
$622,640
69%
$208,960
$74,434
$283,394
3)%
$906,034
0 0
I I
3 i
1 i
3 o
(1)
$130,102
$601.797
$825,023
$88,295
$50,000
$1.695,217 $0
75%
$66,434
$164,130
$54,033
$159,335
$126.917
$570,849 $0
25%
$2.266.066 $0
i § §
I I
i § §
IB z 5>
(2) $56,212 (2)
$759,263
$378.037
$702,685
$1,896,197
83%
$148,289
$70,000
$168,863
$387,152
17%
$2,283,349
ORD Toll I
$487,437
$1,530,250
$4,154,145
$3,194,248
$2,081,920
$1,460,151
$3.303.676
$1,238,196
$17,449,299
67%
$993.124
$829,221
$563.690
$1,354,391
$421,588
$625,515
$220,386
$677,686
$929,530
$966,422
$50,076
$435,306
$352,766
$92,602
$72
$71
$56,070
$69
$8,569,194
33%
$26,016,493
Note: Yearty sums are expressed in purchase year dollars, they have not been inflated to current year dollars.
(1) Laboratory has no equipment with a purchase price greater than $50,000.
(2) Equipment inventory is included in parent laboratory inventory.
4-50
-------
TAB4-13.XLS
Table 4-14. Equipment Inventory Summary (Purchase Price >$50,000)
Program Office Laboratories
Purcheee
Veer
94
93
92
91
90
89
88
87
Subtotal:
Percent of
Total:
86
85
84
83
82
81
80
79
78
77
76
75
74
73
72
71
70
69
Subtotal:
Percent of
Total:
Total:
* 1 1 i
i i i
m y -n 3
c 5 p j
* m E r
| S *
$62,560
$562 .2 66
$675.345 $95,375
$55,474
$56,705
$351.000
O o
3 0 B TJ 0
> PI * 3 "o
' Z o > ~°
; | 1 i i
= 5 § 5 f.
2 «
$151,880 (3) (3) (3)
$207.730
$75,150
$600,613
$66.100
$97,605 $186.786
$1.588,611 $95,375 $174,739 $97,605 $1,288.259
90% (00% 10%
$164,638
$170,396
60% 94%
$161,500
$84,577
$64,254
$75,000
$188,173
$240,000
$76,000
$671,500
$214,000
$170,396 $1,629.311 $64,254 $246,077
10% 90%
40% 16%
$1,759,007 $95,375 $1,804,050 $161.859 $1,534.336
Ofllc* Totil
$270.290
$637,416
$770,720
$55,474
$657.318
$417.100
$284,391
$3,244,589
61%
$164,638
$331.896
$84,577
$64,254
$75,000
$188.173
$240,000
$76,OOO
$671.500
$214,000
$2,110,038
39%
$5,354,627
Note: Yearly sums are expressed in purchase year dollars, they have not been inflated to current year dollars.
(1) Laboratory has no equipment with a purchase price greater than $50,000.
(2) Equipment inventory is included in parent laboratory inventory.
(3) No data provided.
4-51
-------
TAB4-13.XLS
Table 4-15. Equipment Inventory Summary (Purchase Price >$50,000)
Environmental Services Organizations
Purchas*
Year
94
93
92
91
90
89
88
87
Subtotal:
Percent of
Total:
86
85
84
83
82
81
80
79
78
77
76
75
74
73
72
71
70
69
Subtotal:
Percent of
Total:
Total:
R01/NERLAEX
$74.640
$79,650
$100,000
$51.902
$168.769
$135,259
$610,220
75%
$200,000
$200,000
2S%
$810,220
S5|i|S2|2
I I S 1 I 1 § 1 1
">Sfcisa-s
Sis^iissff
(3)
$303,188 $126,483 $181,924
$187,104 $160,000 $216,633 $959,255
$66,095 $165,981 $64,085 $192,016 $128.075
$51.987 $220,616 $92.173
$148,135 $105,000 $374,885 $280,004 $54,357 $141,078
$212,942 $236,011 $233,510 $266,826 $393.250 $87,815 $147,861
$68.288 $77,500 $351.964 $56.086 $122,713
$798,648 $605,615 $1.138.829 $160.000 $933,429 $876.584 $543.622 $1.417,115
62% 53% 85% 29% 42% 100% 61% 83%
$263,986 $140,000 $149,580 $145.000
$62.571 $250,000 $751.670 $204,252
$216,170 $209.500 $141,504
$145,824
$251,400
$66,782 $85,000
$54,900
$100.000 $70,000
$50,000
$172,916
$499.473 $534,352 $204,900 $390.000 $1,265.750 $350.076 $286,504
38% 47% 15% 71% 58% 39% 17%
$1.298,121 $1,139,967 $1,343,729 $550,000 $2.199,179 $876,584 $893,698 $1.703,619
ESO Total
$74,640
$691.245
$1.622.992
$668.154
$533,545
$1.238,718
$1,578,217
$676,551
$7.084.062
66?.
$698,566
$1,468,493
$567,174
$145.824
$251,400
$151,782
$54,900
$170,000
$50,000
$172.916
$3,731.055
34%
$10,815,117
Note: Yearly sums are expressed in purchase year dollars, they have not been inflated to current year dollars.
(1) Laboratory has no equipment with a purchase price greater than $50,000.
(2) Equipment inventory is included in parent laboratory inventory.
(3) No data provided.
4-52
-------
investments of $800,000 to $1,000,000 are required.
Figures 4-12, 4-13, 4-14, and 4-15 provide additional information regarding the
space and occupants of the laboratory facilities.
All of the figures used for equipment costs came from EPA's database. The inventory
was not checked during visits to the laboratories, but some equipment was identified that
was not included in the inventory. Some laboratories had prepared more detailed
inventories for developing specifications for new buildings, but as these were not available
for all laboratories, the agency's official inventory was used. An updated or reengineered
system including data entry procedures may be required to ensure valid data Agency-wide.
4.6 HUMAN RESOURCES
4.6.1 Intramural Resources
During the course of this study, the Agency conducted a companion study referred to
as Workforce '94. Agency employees working in the laboratory organizations were asked
for data such as their degrees, employment level, and the activities they perform. A
separate report will present the complete data set, but excerpts from that data set have
been included in this laboratory study to support the option evaluation.
Figure 4-16 presents the academic degrees reported from GS 9 and above at the ESO
and program office laboratories combined. In the Workforce '94 questionnaire, individuals
were asked to report all of the academic degrees that they have earned. While the data do
not precisely show what skills a person is currently using, they do give an indication of
the expertise resident at a laboratory. The professional profiles for both laboratory types
are similar, with more variety among the program office laboratories, but nonetheless a
common concentration of engineering, biological sciences, and chemistry degrees. That is,
there is no clear differentiation among these two laboratory types to be made on the basis
of their professional staffing. A nearly identical pattern is found for the ORD laboratories,
as shown in Figure 4-17.
The age distribution for staff has been compiled in three different grade groupings and
is shown in Figures 4-18, 4-19, and 4-20. GC1 includes Senior Executive Service (SES)
and GM/GS levels 14 and above (managerial grades); GC2 includes GM/GS grades 9
through 13 (scientists and engineers); and GC3 is less than GM/GS grade 9 (technical and
administrative support). The distribution in each of the three grade groupings are generally
similar; a significant fraction of the staff is in the upper age brackets. Similar figures
prepared for each laboratory appear in Appendix A. The distributions vary greatly from
4-53
-------
FIG4-12.XLS Chart 1 - 5/27/94
180,000
160,000
140,000
If
0)
£ 120,000
3
5 100,000
0)
o 80,000
Q.
CO
^ 60,000 -
'o
40,000 -
20,000 -
HTL
^ Other Space (1)
D Office Space
H Laboratory Space
3 3) 33
Sources: OARM/FMSD; ORD/ORPM; Laboratory Directors
(1) Includes storage, shops, loading docks, conference rooms,
and other special purpose facilities.
Laboratory
Figure 4-12. Facility Space by Laboratory
-------
FIG4-13.XLS Chart 2 - 5/27/94
500 -|
450
I 400
to
Q.
§ 350
O
= 300
o
"5 250 -
J!
E 200
150
2 100
a.
n
oooooooooooooooooooo
3D Tl *n TlTlTlTlTITITlTITITl'nTITITl'n'nTl
m rfl rn rfl
I I S 33
O O O O
- O O
5 5 5 § I
f=S*g|
Sources: ORD/ORPM; Laboratory Dlreclors; WorWorce 94
(1) Based on reported numbers of FTE or extramural work-years,
actual occupancy may be greater.
rfl rtl
I
§
I D
E 5
3 C
8 £
35
CO
r^
>
O
>
5
§ 8 |
5 i §
m
r co
Z D
O O
3*
3 5
? s
s i
o o
ro ro
c/) m
Laboratory
Figure 4-13. Approximate Number of Facility Occupants (Based on Workforce Data)
-------
FIG4-14.XLS Chart 4 - 5/27/94
450,000 -i
400,000 -
|T 350,000
0)
| 300,000
w
'55
Q
la Other Space (1)
D Office Space
H Laboratofy Space
•ti Q 3 " 3 g
i 3? f 1 I
O
I
&
O
o &
u> -t
<6 S
= g-
I
w
Source: See Table 4-12
(1) Includes storage, shops, loading docks, conference rooms,
and other special purpose facilities.
Location
Figure 4-14. Total Facility Space By Location
-------
FIG4-15.XLS Chart 5 - 5/27/94
1200 -,
33
-0
Q.
Q.
B)
o g o
O OB c
2 3 =•
o
c
5
O
s
§'
8 I
Source: See Table 4-12
(1) Based on reported numbers o( EPA FTE and extramural work-years;
actual occupancy may be greater.
O
11
a 8
I
I
Location
Figure 4-15. Approximate Total Facility Occupants By Location
-------
[DISCPLN.XLWJDISC9UPP.XLC
oo
FTE
Chemistry
Physics
Earth Sciences
Phys. Sci., Other
Agric./Soil Sci
Env. Science/ Conservation
Bio-Sciences
Health Pros
Math/Slat.
Engineering
Computer/ Info. Sci
Discipline Interdisciplinary
Business Mgmnt/Admin
Other
Laboratory
Figure 4-16. FTE by Discipline (Degrees) for Program Office Laboratories and Environmental Services Organizations
for all Grades GS9 and Above
-------
(DISCPLN.XLW)DISC9UPO.XLC
Chemistry
Physics
Earth Sciences
Phys. Sci., Other
AgricVSoil Sci.
Env. Science/ Conservation
Bio-Sciences
Health Pros
Math/Stat.
Engineering
Computer/ Info. Sci.
Discipline Interdisciplinary
Business Mgmnt/Admin.
Laboratory
Figure 4-17. FTE by Discipline (Degrees) for ORD Laboratories for all Grades GS9 and Above
-------
CHT4J3.XLC
12% -i
10% -
D GC1=SES, GS/GM 14,15,15+
• GC2=GS/GM 9-13
H GC3=Below 9
186
172
8% -
c
8 6%
£
4%
2% -
0%
Under 26-30 31-35
26
36-40 41-45 46-50 51-55 56-60
Age Range
Over
60
Source: Workforce 94
Figure 4-18. Intramural Workforce Age Distribution
ORD Laboratories
4-60
-------
CHT4 14.XLC
14%
12% -
10% -
8% -
c
o>
u
-------
CHT4J5.XLC
16% -i
14%
12% -
D GC1=SES, GS/GM 14,15,15+
• GC2=GS/GM 9-13
GC3=Below 9
Under 26-30 31-35 36-40 41-45 46-50 51-55 56-60 Over
26 60
Age Range
Source: Workforce 94
Figure 4-20. Intramural Workforce Age Distribution
Environmental Services Organizations
4-62
-------
laboratory to laboratory, some laboratories having large percentages of their staff in the
categories above 45 years old.
Employee activities are summarized by percent of work year and presented in
Tables 4-16, 4-17, and 4-18. These tables show the distribution of activities by four major
functions and provide detailed comparison data on workforce activities across all
laboratories.
Appendix A contains information on characteristics of employees eligible for
retirement in the next seven years for each laboratory. No summary table has been
prepared for this information.
Tables 4-19, 4-20, and 4-21 give summaries of the disciplines in which ORD
laboratory staff and program office and ESO staff hold degrees. The total is the number of
degrees reported; if a staff member holds bachelor, master, and doctorate degrees, three
degrees would be counted. For this reason, the total number of degrees is greater than the
total number of staff at the laboratories.
4.6.2 Extramural Resources
Laboratory staff were asked to provide information regarding their on-site extramural
FTEs. These data are presented for the ORD laboratories in Table 4-22 and show that the
total extramural force is about the same size as the intramural workforce. Data for the
program offices and ESOs are shown in Table 4-23. The program office laboratories
reported only 15 percent of their on-site workforce as extramural and the ESOs reported
34 percent as extramural. Figure 4-21 summarizes the intramural and extramural work
year equivalents for each laboratory. The percent of intramural and extramural work years
is displayed in Figure 4-22 for each laboratory reporting both intramural and extramural
work years. The laboratories are arranged by type (ORD, program office, and ESO). Of
the ORD laboratories, the two Environmental Criteria and Assessment Offices (ECAOs)
and the RREL report greater than 60 percent of their total work years delivered by EPA
staff. Of the program office laboratories and ESOs shown with data, the majority reported
greater than 60 percent of their total work years delivered by EPA staff.
4-63
-------
TAB4 16 XLS
Table 4-16. Percentage Distribution of Reported Work Activities
ORD Headquarters Offices and Laboratories
Work Activity
Management, Policy and Planning Functions
Science and Engineering Functions
Science and Engineering Management
General Management Responsibilities
Bench Science, Engineering, Modeling
Scientific Analysis and Interpretation
Extramural Management
Technical Oversight and Project Direction
Administrative Tasks
Technology Transfer
Technical Assistance
Quality Assurance
Other
Technical Support to Science Functions
Administrative Functions
Total:
ORD/HQ/EMAP
46%
31%
8%
8%
8%
8%
23%
100%
ORD/HQ/IOAA
28%
8%
3%
3%
3%
8%
56%
100%
ORD/HQ/OEETD
47%
11%
5%
5%
42%
100%
ORD/HQ/OEPER
62%
5%
33%
100%
ORD/HQ/OER
21%
29%
14%
14%
7%
43%
100%
ORD/HQ/OHEA
12%
29%
6%
6%
6%
6%
6%
18%
41%
100%
ORD/HQ/OHR
27%
27%
9%
9%
9%
45%
ORD/HQ/OMMSQA
50%
19%
4%
4%
4%
4%
4%
8%
23%
100%| 100%
ORD/HQ/ORPM
45%
2%
53%
100%
ORD/HQ/OSPRE
30%
29%
1%
1%
4%
3%
1%
12%
5%
22%
19%
ORD/AEERL7RTP
14%
54%
4%
1%
7%
7%
14%
8%
6%
4%
3%
12%
20%
100%| | 100%
ORD/AREAL7RTP
13%
59%
4%
2%
12%
13%
8%
5%
4%
6%
5%
11%
17%
100%
ORD/EAG/DC
13%
81%
6%
13%
25%
13%
6%
6%
13%
6%
100%
ORD/ECAO/CIN
12%
54%
5%
5%
20%
7%
2%
5%
7%
2%
17%
17%
100%
ORD/ECAO/RTP
10%
65%
3%
3%
32%
6%
3%
6%
10%
3%
23%
100%
Source: Workforce '94
-------
Table 4-16. Percentage Distribution of Reported Work Activities (Concluded)
ORD Headquarters Offices and Laboratories
Work Activity
Management, Policy and Planning Functions
Science and Engineering Functions
Science and Engineering Management
General Management Responsibilities
Bench Science, Engineering, Modeling
Scientific Analysis and Interpretation
Extramural Management
Technical Oversight and Project Direction
Administrative Tasks
Technology Transfer
Technical Assistance
Quality Assurance
Other
Technical Support to Science Functions
Administrative Functions
Total:
ORD/EMSL/CI
z
15%
58%
3%
2%
16%
14%
5%
4%
3%
4%
6%
8%
19%
100%
ORD/EMSIA
<
14%
42%
4%
1%
7%
7%
7%
6%
1%
5%
4%
22%
23%
100%
ORD/ERL7AD
>
15%
49%
3%
2%
11%
8%
7%
5%
3%
8%
2%
13%
23%
100%
ORD/ERL/AT
I
9%
51%
3%
3%
16%
11%
4%
5%
3%
4%
3%
15%
25%
100%
ORD/ERL/CO
3)
12%
58%
6%
3%
15%
13%
6%
6%
1%
3%
4%
15%
15%
100%
ORD/ERL/DU
r~
7%
59%
4%
2%
23%
14%
4%
3%
2%
2%
3%
22%
12%
100%
ORD/ERL/DUL/L
i—
3)
CO
80%
20%
20%
20%
20%
20%
100%
ORD/ERL/GE
VJW
10%
49%
3%
2%
21%
11%
5%
2%
2%
2%
3%
19%
22%
100%
ORD/ERL/NAF
31
16%
57%
5%
20%
16%
4%
4%
4%
4%
2%
11%
16%
100%
ORD/ERL/NARR
-o
m
CD
72%
6%
22%
17%
6%
6%
6%
11%
17%
11%
100%
ORD/HERL/R1
=3
8%
51%
3%
2%
21%
14%
4%
2%
1%
2%
2%
23%
18%
100%
ORD/HHAG/D
O
7%
80%
3%
3%
3%
37%
7%
3%
7%
13%
3%
13%
100%
ORD/RREL/CI
z
15%
47%
4%
1%
8%
7%
9%
6%
4%
6%
2%
17%
21%
100%
ORD/RREL/RCB/
m
a
CO
5%
81%
5%
10%
5%
5%
14%
14%
14%
14%
10%
5%
100%
Source: Workforce '94
-------
TAB4-16XLS
-^
0\
Table 4-17. Percentage Distribution of Reported Work Activities
Program Office Laboratories
Work Activity
Management, Policy and Planning Functions
Science and Engineering Functions
Science and Engineering Management
General Management Responsibilities
Bench Science, Engineering, Modeling
Scientific Analysis and Interpretation
Extramural Management
Technical Oversight and Project Direction
Administrative Tasks
Technology Transfer
Technical Assistance
Quality Assurance
Other
Technical Support to Science Functions
Administrative Functions
Total:
O
z
D
m
^
o
H
7%
54%
2%
2%
15%
12%
5%
2%
7%
7%
17%
22%
100%
0
5
z
-^
m
c;
£
29%
41%
6%
3%
6%
9%
3%
3%
6%
3%
3%
6%
24%
100%
O
1
J*
o
-0
CO
ffl
CD
T3
19%
81%
14%
5%
5%
5%
10%
5%
10%
14%
10%
5%
100%
o
•TJ
g
pa
•-C
<
55%
9%
18%
9%
9%
9%
9%
36%
100%
O
^
m
O
o
m
z
10%
50%
5%
1%
6%
16%
1%
1%
4%
9%
6%
18%
22%
100%
O
o
^~1
CO
o
z
21%
50%
4%
8%
8%
4%
8%
13%
4%
13%
17%
100%
O
T3
T)
O
c~
63
m
w
50%
19%
19%
6%
6%
31%
19%
100%
0
-o
T3
ft
O
C
CD
CO
r~
9%
55%
27%
9%
9%
9%
27%
9%
100%
Source: Workforce '94
-------
Table 4-18. Percentage Distribution of Reported Work Activities
Environmental Services Organizations
Work Activity
Management, Policy and Planning Functions
Science and Engineering Functions
Science and Engineering Management
General Management Responsibilities
Bench Science, Engineering, Modeling
Scientific Analysis and Interpretation
Extramural Management
Technical Oversight and Project Direction
Administrative Tasks
Technology Transfer
Technical Assistance
Quality Assurance
Other
Technical Support to Science Functions
Administrative Functions
Total:
33
o
Z
m
33
1
m
X
18%
56%
4%
2%
18%
7%
2%
2%
11%
9%
27%
100%
33
o
fc£
m
CO
O
m
o
(n
14%
74%
2%
2%
21%
7%
5%
2%
12%
23%
12%
100%
33
o
s
33
C
>
z
Z
19%
56%
4%
2%
4%
14%
5%
4%
4%
9%
12%
25%
100%
33
m
CO
3
>
3
i
10%
40%
2%
1%
5%
10%
2%
1%
3%
9%
7%
29%
21%
100%
jj
Q
Si
CO
0
Q
I
14%
46%
3%
1%
4%
14%
3%
1%
3%
7%
9%
14%
25%
33
0
§
CO
O
"T
O
c
14%
49%
4%
1%
3%
15%
1%
1%
3%
8%
12%
11%
26%
100%J100%
33
0
-4
rfi
co
o
7;
>
z
7%
52%
4%
3%
6%
20%
3%
3%
3%
4%
6%
7%
33%
100%
33
o
?
m
co
D
O
m
z
20%
48%
12%
16%
4%
4%
8%
4%
12%
20%
100%
33
O
§
CO
5
33
O
5%
71%
5%
5%
5%
10%
10%
5%
14%
19%
24%
100%
33
O
m
CO
D
CO
m
>
7%
63%
3%
1%
4%
35%
3%
1%
4%
4%
4%
1%
15%
15%
100%
Source: Workforce '94
-------
[DISCPLN.XLWJTAB4-19.XLS
Table 4-19. Number of Degrees (GS9 and Above)
ORD Laboratories
Discipline
Chemistry
Chemistry, General
Analytical Chemistry
Inorganic Chemistry
Organic Chemistry
Chemistry, Other
Physics
Earth Sciences
Geological Sciences
Oceanography
Atmospheric Sciences
Physical Sciences, Other
AgriculturaUSoil Sciences
Environmental Science/ Resource Conservation
Biological Sciences
Biology
Plant Biology
Biochemistry/Cell Biology/Genetics
Microbiology/Bacteriology/Virology
Ecology
Marine/Aquatic Biology
Toxicology/Pharmacology
Physiology/Anatomy/Pathology
Biotechnology
Zoology
Entomology
Biological Sciences, Other
Health Professions
Mathematics/Statistics
Engineering
Chemical Engineering
Mechanical Engineering
Civil/Environmental Engineering
Engineering, Other
Computer and Information Sciences
Interdisciplinary
Business Management and Administration
Other
No Response
Total Number of Degrees:
O
|
m
rri
33
C
-D
9
4
1
1
3
3
4
2
2
2
1
1
1
60
24
18
19
1
10
9
175
0
33
D
33
m
C
33
49
15
5
13
37
18
2
1
4
3
10
3
2
2
1
2
2
7
14
16
3
12
14
2
11
12
260
O
33
D
C)
0
2
2
2
1
3
2
1
1
1
1
5
2
5
2
30
0
33
O
rn
O
pj*
8
o
•z.
2
1
2
11
3
4
4
9
2
3
6
10
4
1
1
1
3
3
5
75
O
33
0
m
5
33
— \
3
2
2
1
6
5
4
1
11
2
3
1
4
5
1
2
3
15
71
0
33
g
m
(S>
f^.
o
•z
36
10
4
11
1
2
21
2
16
22
8
2
3
2
10
11
3
6
4
3
6
2
1
4
7
10
207
O
33
m
S
C/3
C
r-
33
14
2
16
16
7
18
1
3
10
16
7
5
7
4
3
2
4
1
4
4
14
2
1
3
11
5
5
8
22
248
O
33
D
m
C/3
r-
r"
rn
o
O
3)
m
33
C
a
11
1
1
2
6
1
7
1
2
9
1
2
1
1
5
4
1
18
4
1
3
5
3
90
O
n
§
u
C
S
— (
I
19
5
1
7
16
1
3
8
1
5
12
5
3
4
3
1
5
8
11
2
1
3
6
130
Source: ORD/ORPM (Workforce '94)
Note: Each FTE may have more than one degree/discipline.
4-68
-------
[DISCPLN.XI_WJTAB4-19.XLS
Table 4-19. Number of Degrees (GS9 and Above) (Concluded)
ORD Laboratories
Discipline
Chemistry
Chemistry, General
Analytical Chemistry
Inorganic Chemistry
Organic Chemistry
Chemistry, Other
Physics
Earth Sciences
Geological Sciences
Oceanography
Atmospheric Sciences
Physical Sciences, Other
Agricultural/Soil Sciences
Environmental Science/ Resource Conservation
Biological Sciences
Biology
Plant Biology
Biochemistry/Cell Biology/Genetics
Microbiology /Bacteriology/Virology
Ecology
Marine/Aquatic Biology
Toxicology/Pharmacology
Physiology/Anatomy/Pathology
Biotechnology
Zoology
Entomology
Biological Sciences, Other
Health Professions
Mathematics/Statistics
Engineering
Chemical Engineering
Mechanical Engineering
Civil/Environmental Engineering
Engineering, Other
Computer and Information Sciences
Interdisciplinary
Business Management and Administration
Other
No Response
Total Number of Degrees:
O
x
g
m
X
o
0
X
1
1
3
1
2
3
17
20
6
7
14
7
1
7
7
1
4
3
2
2
1
4
5
119
o
x
o
x
r-
C
r-
11
5
2
1
8
3
34
4
4
1
14
17
13
4
14
2
9
1
2
1
3
2
4
159
0
x
m
33
pi
C
p:
I —
X
CO
1
1
2
2
3
1
4
14
O
x
m
x
S
CO
5
2
1
1
1
32
2
8
13
3
14
5
4
7
2
7
1
2
1
2
2
2
4
3
124
0
ID
D
m
X
i
x
x
1
1
2
7
5
11
15
7
2
5
16
3
2
1
3
9
2
2
5
4
2
6
11
122
O
x
g
m
x
^
x
x
-D
m
CO
4
1
1
1
2
5
1
1
10
3
1
1
13
1
1
2
48
O
x
0
I
m
x
C
x
-D
20
2
8
8
11
1
2
64
4
44
20
2
51
45
1
21
2
29
29
28
3
5
11
S
5
12
49
482
O
x
5
i
o
D
O
4
1
1
3
14
3
1
7
7
4
1
4
11
9
2
72
O
x
g
x
X
m
r~
O
z
21
9
4
7
7
2
5
2
13
5
14
6
1
2
5
8
50
16
69
14
6
3
21
18
308
O
x
g
x
x
m
C
x
o
5
m
o
CO
2
3
1
2
2
2
1
4
2
12
4
2
2
39
O
33
O
£.
234
73
21
71
104
59
53
28
9
28
272
47
128
113
66
82
114
72
2
81
10
97
83
104
150
56
171
105
27
34
101
178
2773
Source: ORD/ORPM (Workforce '94)
Note: Each FTE may have more than one degree/discipline.
4-69
-------
pSCPLN.XLWrrAB4.2o.XLS
Table 4-20. Number of Degrees (GS9 and Above)
Program Office Laboratories
Discipline
Chemistry
Chemistry, General
Analytical Chemistry
Inorganic Chemistry
Organic Chemistry
Chemistry, Other
Physics
Earth Sciences
Geological Sciences
Oceanography
Atmospheric Sciences
Physical Sciences, Other
Agricultural/Soil Sciences
Environmental Science/ Resource Conservation
Biological Sciences
Biology
Plant Biology
Biochemistry/Cell Biology/Genetics
Microbiology /Bacteriology/Virology
Ecology
Marine/Aquatic Biology
Toxicology /Pharmacology
Physiology/Anatomy/Pathology
Biotechnology
Zoology
Entomology
Biological Sciences.Other
Health Professions
Mathematics/Statistics
Engineering
Chemical Engineering
Mechanical Engineering
Civil/Environmental Engineering
Engineering, Other
Computer and Information Sciences
Interdisciplinary
Business Management and Administration
Other
No Response
Total Number of Degrees:
2
5
z
*>
3
i
—I
5
1
1
2
5
2
1
4
1
1
1
5
1
1
1
3
8
43
O
5
^>
~u
en
rn
3
~D
1
3
8
4
3
1
2
22
O
^
5
z
-q
m
1
1
2
3
2
1
3
12
2
3
15
10
54
O
>
5
33
<
2
2
1
2
1
1
9
O
^
m
o
s
m
z
26
5
1
2
7
1
4
2
1
2
2
2
3
2
7
5
3
9
11
27
4
5
1
15
25
172
O
O
£
D
£
^
en
g
o
z
5
3
5
2
1
1
1
14
32
O
-D
^
0
C
CO
m
—t
CO
10
2
1
1
1
1
1
1
1
19
0
-D
-D
rn
O
C
CO
CO
1—
5
3
1
2
2
3
1
2
1
2
1
1
4
28
T)
O
(O
D
3
~£
o"
e
H
o
~
51
14
1
10
14
10
6
2
2
6
14
2
2
4
3
2
2
7
7
9
16
18
21
47
13
6
3
36
51
379
Source: ORD/ORPM (Workforce '94)
Note: Each FTE may have more than one degree/discipline.
4-70
-------
[DISCPLN.XLWJTAB4-21.XLS
Table 4-21. Number of Degrees (GS9 and Above)
Environmental Services Organizations
Discipline
Chemistry
Chemistry, General
Analytical Chemistry
Inorganic Chemistry
Organic Chemistry
Chemistry, Other
Physics
Earth Sciences
Geological Sciences
'Oceanography
Atmospheric Sciences
Physical Sciences, Other
Agricultural/Soil Sciences
Environmental Science/ Resource Conservation
Biological Sciences
Biology
Plant Biology
Biochemistry/Cell Biology/Genetics
Microbiology /Bacteriology/Virology
Ecology
Marine/Aquatic Biology
Toxicology /Pharmacology
Physiology/Anatomy/Pathology
Biotechnology
Zoology
Entomology
Biological Sciences.Other
Health Professions
Mathematics/Statistics
Engineering
Chemical Engineering
Mechanical Engineering
Civil/Environmental Engineering
Engineering, Other
Computer and Information Sciences
Interdisciplinary
Business Management and Administration
Other
No Response
Total Number of D»gre«s:
i
m
33
C
m
X
9
10
1
5
1
4
7
3
2
3
1
1
1
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2
3
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2
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3
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11
4
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3
3
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z
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4
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1
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122
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6
7
13
2
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13
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9
134
33
m
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14
3
1
3
3
4
1
2
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4
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4
6
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14
8
2
1
6
5
109
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D
S
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Z
29
6
2
8
1
7
1
3
2
1
1
2
3
6
1
19
3
2
1
6
13
117
33
O
S
m
17
7
4
11
1
3
1
4
1
2
3
1
3
4
9
6
1
1
4
7
90
ffi
w
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2
SL
148
54
14
28
35
5
34
1
7
10
64
9
15
16
13
25
9
3
12
2
19
18
8
43
8
106
38
11
9
41
64
869
Source: ORD/ORPM (Workforce'94)
Note: Each FTE may have more than one degree/discipline.
4-71
-------
[XTRA-SUMJCLWltabtos 4-21,4-22
Table 4-22. On-Site Intramural and Extramural Workforce Summary
ORD Laboratories
Laboratory
ORD/AEERL/RTP
ORD/AREAL/RTP
ORD/EMSL/CIN
ORD/EMSL/LV
ORD/EMSLAV/EPIC
ORD/HERL/RTP
ORD/ERL/ADA
ORD/ERL/ATH
ORD/ERL/COR
ORD/ERL/DUL
ORD/ERUDUL/LLRS
ORD/ERL7GB
ORD/ERL/NARR
ORD/ERL/NARR/PEB
ORD/EAG/DC
ORD/ECAO/CIN
ORD/ECACYRTP
ORD/HHAG/DC
ORD/RRELyCIN
ORD/RREURCB/EDIS
ORD Totals:
Extramural Mechanism (1)
Cooperative
Contract Agreement Reimbursable Other
Work-Yean Work-Year* Work-Yean Work-Yean
53 24
110 26 45
74 20 13 1
40 38 40
12 2
181 75
52 10 11
19 26 13
149 41 9 2
36 12 21
15 3 6
55 77
68 29 19
17 5
1 1 1
10 4
12 2
1 3 1
55 35 11
5 3
963 433 147 45
Extramural
Total
Work-
Yean Percenf
77 43%
180 52%
107 47%
118 44%
14 57%
257 53%
73 56%
58 44%
201 76%
69 46%
24 78%
131 69%
116 68%
22 57%
3 76%
13 25%
14 30%
5 14%
101 33%
8 22%
1588 57%
Intramural (2)
FTE Percenf
102 57%
166 40%
119 53%
151 56%
10 43%
227 47%
56 44%
74 56%
64 24%
80 54%
7 22%
58 37%
54 32%
21 49%
16 84%
39 75%
32 70%
31 86%
203 67%
28 78%
1535 49%
Total
Work-Year
Equivalent*
178
346
226
268
24
483
129
132
265
149
30
189
170
42
19
52
45
36
304
36
3123
Notes:
(1) Source: Workforce S4
(2) Source: ORD/ORPM (ORD); Uboratory/ESO Directors (Program Office Laboratories and Environmental Services Organizalions)
4-72
-------
pOHA-SUMJ(LW]tabl«s 4-21. 4-22
Table 4-23. On-Site Intramural and Extramural Workforce Summary
Program Office Laboratories and Environmental Services Organizations
Laboratory
Program Office
OAR/NAREL/MONTT
OAR/OAQPS/EMB/RTP
OAR/OMS/NVFEL/AA
OAR/ORIA/LV
OE/NEIC/DEN
OGWDW/TSD/CIN
OPP/ACL/BELTS
OPP/ECUBSL
Program Office Total*:
ESQ.
R01/NERL/LEX
R02/ESD/EDIS
R03/CRL/ANN
R04/ESD/ATH
R05/ESD/CHI
R06/ESD/HOU
R07/ESD/KAN
R06/ESD/DEN
R09/ESB/RICH
R10/ESD/SEA
ESO Total*:
Extramural Mechanism
Coop«nUv*
Contract AgrMrmnt RtfmburuM* Othw
Work-Yuri Work-Yuri Work-YMre Work-Yuri
10 9
0
53 32 2 0
1 8.2 1
35 18
522
2
104 71 5 0
10
7 1
45 4 19
33
41 21
31
31 7
13 4
22 5
46 3 10
279 16 29 29
Extramural
Work-
YMP» Ptrctnt
19 33%
0 1%
88 24%
10 4O%
53 30%
9 27%
0 0%
2 9%
180 25%
10 16%
8 8%
68 52%
33 23%
62 43%
31 46%
38 32%
17 40%
27 56%
59 42%
352 36%
Intramural
FTE Percent
39 67%
25 99%
277 76%
16 60%
120 70%
23 73%
17 700%
17 91%
534 75%
51 84%
86 92%
63 45%
113 77%
82 57%
36 54%
82 68%
25 6O%
21 44%
81 58%
639 64%
Total
Work-Y*ar
Equivalent*
59
25
365
26
173
32
17
19
714
61
93
131
146
144
67
120
42
46
140
992
Notes:
(1) Source: Workforce 94
(2) Source: ORD/ORPM (ORD); Laboratory/ESO Directors (Program Office Laboratories and Environmental Services Organizations)
4-73
-------
[XTRA-SUM.XLW]sort table Chart 1
5/27/94
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ORD/ORPM; Laboratory/ESO Directors (FTE)
re Function FTE)
Services FTE)
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nl m rft ^ rh rrl
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Figure 4-21. Laboratory Workforce Distribution
(Intramural and Extramural)
-------
[XTRA-SUM.XLW]sort table Chart 2
5/27/94
Intramural
I Intramural (ESO Analytical Services) D Intramural (Other ESO Core Functions) E] Extramural
-0
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Sources: Workforce '94 (Extramural data)
ORD/ORPM; Laboratory/ESO Directors (FTE data)
Laboratory
Figure 4-22. Relative Size of Intramural and Extramural Workforce By Laboratory
-------
SECTION 5
ISSUES AND CUSTOMERS
Work conducted at the laboratories within the EPA system effects and is used by a
wide variety of individuals and organizations. The word customer is used in a broad sense
including laboratory personnel as well as individuals and organizations both internal and
external to EPA. Internal EPA customers start with the other scientists and engineers
within the laboratory system and other portions of the ESOs and extend to the staff of the
headquarters and regional EPA program offices. External customers begin with the public,
with whose protection EPA is charged, and its representatives, including elected officials,
public interest and civic groups, tribal, state, local, and other federal agencies. The work
of the laboratory system extends into the academic community, the regulated community,
the media, and internationally to neighboring governments in Canada, Mexico, the
Caribbean, and the rest of the international environmental community.
Participants in the study were asked for information on the relationship between users
and providers of information and services coming from the laboratory system for a
description of their needs as customers and how the existing laboratory system is or is not
meeting those needs and for any issues relating to the administration, organization, and
conduct of laboratory activities.
Information for this part of the study was gathered through laboratory visits and
interviews with a wide variety of EPA customers as well as a review of existing
documentation. These interviews included senior EPA executives, EPA staff members in
the various program offices at both headquarters EPA and in the regional EPA offices,
laboratory personnel, management and staff at state laboratories, and management and
staff at private laboratories. The following sections will examine the issues raised by both
internal and external customers of the laboratory system and will summarize these issues
for use in evaluating the study options.
In addition, MITRE acted upon a recommendation of the NAPA Advisory Panel to visit
several laboratories in the private sector to gain an impression on how these organizations
organize and conduct their R&D activities and to tour laboratory facilities to discern if
EPA's laboratories are comparable in terms of facilities and equipment. Due to schedule
and cost limitations, only three organizations were visited, and the length of the visit was
limited to a single day with two MITRE staff participating. While the information base is
by no means comprehensive, the observations made with respect to organizational
philosophies and operating practices are worth considering in the evaluation of EPA's
laboratory options.
5-1
-------
5.1 CUSTOMERS
The ORD laboratories provide research support for headquarters and regional program
offices in the implementation of EPA's regulatory programs. Because many of these
programs are delegated, state and tribal regulatory staff are also customers of the ORD
system. The ORD laboratories network of customer extends beyond the regulators to
encompass those affected by the regulations, including the public and their elected
representatives, the regulated community, elected officials, civic and environmental
organizations, other state and federal agencies, and the media. Through their more
fundamental research on underlying science questions and emerging issues, the
laboratories have additional customers in the academic community and internationally. A
consolidated list of customers for the ORD laboratories is provided in Table 5-1. This list
was drawn from the individual customer lists in the information on each laboratory in
Appendix A.
The program office laboratories provide focused support to their sponsoring program
offices. Directly connected with their primary customers in the program offices and
frequently in direct with the regulated community governed by those programs, the
program office laboratories serve not only this immediate customer base, but additional
customers both internal and external to EPA who require scientific knowledge within the
areas of expertise of the specific program office laboratory. Detailed lists of customers for
the program office laboratories can be found as part of the laboratory descriptions in
Appendix A.
Within the ten regional offices, the ESOs provide a wide variety of types of support to
their customers. These activities vary depending upon the organizational structure of the
regional offices, but the three core functions of laboratory services, QA/QC, and field
monitoring are consistently provided through most of the ten EPA Regions. A
consolidated list of customers for all ten Regions is provided in Table 5-2. This list was
drawn from the individual customer lists found with the information on each individual
laboratory found in Appendix A.
5-2
-------
Table 5-1. Consolidated ORD Customer List
INTERNAL EPA*
Office of Administration and Resources Management
Safety and Health Environmental Management Division
Office of Air and Radiation
Office of Enforcement
Office of Information Resources Management
Office of International Activities
Office of Policy, Planning and Evaluation
Office of Prevention, Pesticides and Toxic Substances
Office of Research and Development
Office of the Assistant Administrator
Office of Environmental Engineering and Technology Demonstration
Office of Environmental Processes and Effects Research
Office of Modeling, Monitoring Systems and Quality Assurance
ORD Laboratories (laboratories are customers to each other)
Office of Science and Technology
Engineering Analysis Division
Health and Ecological Criteria Division
Office of Solid Waste and Emergency Response
Office of Emergency and Remedial Response
Office of Solid Waste
Office of Underground Storage Tanks
Hazard Site Evaluation Division
Emergency Response Division
Superfund Innovative Technologies Program
Office of Water
Office of Groundwater and Drinking Water
Drinking Water Standards Division
Technical Support Division
Enforcement and Program Implementation Division
Office of Science and Technology
Health and Ecological Criteria Division
* Note: EPA as a whole is a customer for ORD. The portions of the Agency listed
here specifically received or commissioned products or services produced by the
laboratories.
5-3
-------
Table 5-1. Consolidated ORD Customer List (Continued)
INTERNAL EPA (concluded)
Office of Wastewater Enforcement and Compliance
Permits Division
Office of Wetlands, Oceans and Watersheds
National Estuary Program
Chesapeake Bay Program
Great Lakes Program
Risk Assessment Forum
Science Advisory Board
EPA Regional Offices (Regions 1 to 10)
EXTERNAL
Other federal agencies
Department of Agriculture
Forest Service
Food and Drug Administration
Department of Defense
Army, Ft. Detrick, MD
Army Corps of Engineers (New England Division, New York District, and WES)
Navy (NCCOSC and NOSC San Diego)
Department of Energy
Department of Interior
Bureau of Minerals Management
Bureau of Mines
Bureau of Reclamation
U.S. Fish and Wildlife Service
National Oceanic and Atmospheric Administration
Northeast Fisheries Center
Coast and Geodetic Survey
U.S. Geological Survey
Department of Justice
General Services Administration
National Aeronautics and Space Administration
5-4
-------
Table 5-1. Consolidated ORD Customer List (Concluded)
EXTERNAL (concluded)
Other Governmental Customers
Native American governments
State governments (i.e., Alaska Fish and Wildlife, California Fish and Game)
Local governments (i.e., City of Los Angeles; Wayne County, Michigan)
New South Wales Pollution Control Commission, Australia
Canada
Other
Congress
Academic and scientific community
Public
Regulated community
Technology and assessment application community
5-5
-------
Table 5-2. ESO Customer List
INTERNAL
Primary Customers
Secondary Customers
EXTERNAL
Primary Customers
Secondary Customers
Regional Administrator
Deputy Regional Administrator
Management Division Director
Line Program Division Directors
Regional staff, including ESO personnel
Office of the Inspector General
Criminal investigators
Office of Regional Counsel
Office of External Programs
National ESO/Office of Regulatory Operations and State/Local
Relations Associate Administrator
Headquarters AAs/National Program Managers
ORD Laboratories
NEIC
Relevant state and Native American government programs (such
as environmental, health, agriculture programs)
Regulated community (recognizing ESO's portion of total EPA
role)
Local/regional governments
The public
Volunteer monitoring groups
Other federal agencies
Academic community
Commercial environmental laboratories
Contractors
General Services Administration
Region-specific entities, e.g., Environment Canada, SEDSOL
Public interest groups
The media
Congress/regional delegation
5-6
-------
5.2 COMMENTS AND ISSUES
The issues raised during the laboratory visits and customer interviews can be broken
into four issue categories: mission focus, expectations, locus of control, and
administrative impediments. The following sections will discuss these consolidated issues.
5.2.1 Mission Focus
Laboratory personnel, EPA executives, and the customers of the ORD laboratory
system all raised the issue of the focus of the mission of the ORD laboratories. Two
primary elements of the mission, short-term support for EPA's regulatory mission and
long-term support for EPA's overall environmental mission, were raised as competing
interests by many of the study participants. There was no denial of the usefulness of either
type of activity by any party, but depending upon their involvement in day-to-day
implementation of the Agency's legal and regulatory mandates, the participants
emphasized the value of one element of the mission over the other.
A second aspect of this competition raised during the study was the question of the
primary customer of ORD's work. Again the respondents split into two groups with one
advocating that the scientific needs of the general academic and public community come
first, while the second group advocated the various implementing offices and their needs
as the primary customer for ORD.
For the program office laboratories, the issue of mission focus is in many ways a
mirror image of that of the ORD laboratories. Mission focus for the program office
laboratories is controlled directly by the program office to which they report. The
potential for ambiguity comes with the division of activities between the program office
laboratories and the ORD laboratories. The work performed by the program office
laboratories tends to be tightly focused on specific needs of the program. Broader research
and research into issues that are not specifically covered by a legal or regulatory mandate
tend to be left to the ORD labs. The issue remaining is the method of selecting which are
specific program needs and which are fundamental research.
The program elements that make up ESOs in the ten regions serve an active role in
the implementation of EPA's programs through the support of the implementing offices
within the regional offices, the states, and the Native American governments. As the
statement of the mission of ESOs developed by representatives of the ten regions shows
(see Appendix A), the nature of this support is broad both in its scope and in the variety
of tasks. By virtue of their intimate association with the implementing offices, ESOs
incorporate at the most fundamental level the needs of their customers. Focused as they
are on providing direct support, mission issues raised for ESOs are concentrated on the
5-7
-------
assignment of functions to be performed by ESOs as opposed to having these functions
performed within the various regional program divisions. The question of assignment of
functions and performance of those functions is slightly different for each of the core
functions. Mission focus for the ESO core functions is discussed individually for each
function.
Provision of laboratory services is not a unique function of the ESOs. Various
programs have access to commercial laboratories, state laboratories, and other federal and
EPA laboratories, including ORD, program office, and ESO laboratories in other regions.
Given the variety of potential sources of laboratory services, the issue becomes one of
determining a method for selection of the most efficient provider of laboratory services,
while meeting the expectations of the users of ESOs.
The primary issue raised about QA/QC activities performed by ESOs was an
organizational one. Residing for the most part in separate ESOs, QA/QC offices escape
any loss of objectivity related to reporting to the same Division Directors as the program
offices during the review of work originating in other divisions. This is not true, however,
of QA/QC reviews of work performed within ESOs. Whether perceived or real, the
potential for bias involving review of work produced by the same division within which
the QA/QC offices reside remains. The current system does provide for some external
check on quality through externally managed quality programs such as the use of blind
performance evaluation samples.
The extent of field monitoring activities varies from region to region depending upon
the needs of the regional offices and the resources available. The issue raised was one of
the appropriate location for these activities. Two factors compete within this issue, the
needs and expectations of the individual programs such as air, water, hazardous waste,
pesticides, and toxics, and the wider need of EPA for multimedia information.
5.2.2 Expectations
Expectations for ORD's work ran high from all quarters. EPA program offices expect
support in resolution of scientific and technological difficulties encountered in
implementation of EPA's programs. This is particularly true of program offices that do
not have their own laboratories. Even program offices that have laboratories within their
organizations expect ORD support for research in areas not covered by their own
laboratories. EPA executives expect ORD to provide the science to support the policy
decisions and regulatory rule making that guide EPA's work. There is also a general
expectation that ORD will help provide basic information on environmental issues
important to the public and that ORD will also do advance research on emerging
environmental issues.
5-8
-------
The general public, public officials at all levels, and EPA administration also expect
ORD to provide scientific and technological support for unanticipated or emergency
situations. The health risks associated with exposure to river sediments during the midwest
floods and the "killer carpet" investigations involving indoor air and exposure to chemical
fumes serve as examples of these types of situations.
Study participants also expressed an expectation that ORD would provide multiyear
research into specific scientific or technological problems facing the implementing
program offices. ORD is also expected to use its technical knowledge to provide support
to staff implementing EPA programs and to users of the methods and technologies
developed or studied by ORD.
Because of the direct connection between the program offices and their laboratories,
the expectations of these two parts of the organization are much more closely aligned than
those of ESOs or ORD and their respective clients. The expectations of the program
offices for their associated laboratories are also constrained by the resources that the
program offices devote to the laboratories. The program offices know what resources are
available to the program office laboratories and how they are expended. There are no
feelings of desired work being of low priority or any fears of diverted resources that are
expressed by customers in the other two study areas. This close marriage of expectation
and performance is reflected in the generally high level of satisfaction found in the
relationships between the program office laboratories and their parent programs.
The activities performed by ESOs depend directly on the expectations and demands of
the implementing program offices and their related customers. Regional administrators, in
response to the public and its elected representatives, expect the support of ESOs in
responding to unplanned needs for environmental information on events affecting the
public. Individual regional program offices expect support for implementation of their
individual programs, response to requirements of headquarters program offices, and
execution of unplanned activities.
Participants in the study also raised the issue of changing and increasing demands on
ESOs. The development of new environmental programs and the expansion of existing
programs leads to demands for new services, including the analysis of air toxics,
additional Phase n and Phase V drinking water parameters, increased ecological sampling
and analysis, and work in support emerging environmental programs. The regional
program offices also expect support for special types of analyses and non-routine sample
types often involving more difficult analyses for items like low-level metals, dioxins, and
asbestos that require specialized skills and equipment. Combining these expectations with
the pace of changing technologies for laboratory sample preparation and analysis raises
5-9
-------
the issue of how to meet these expectations across all ten regions when the demand for
these services is not evenly distributed either geographically or temporally.
ESOs are also expected to provide technical support to state and tribal environmental
agencies and to coordinate with the regulated community. This raises the issue of location
and the ability to develop working relationships with customers outside of EPA. ESOs is
also expected to provide even greater levels of support in areas where EPA programs have
not been delegated or in which recipients of delegated programs lack experience or
resources to implement the delegated programs. Again the issues of location and
communication arise.
5.2.3 Locus of Control
All three type of laboratories have problems related to locus of control, but each type
is different because of the different sources of funding. At the ORD laboratory level,
many of the participants raised the issue of micro-management by ORD headquarters,
which provides most of the funding for the laboratories. The distinctions between the
relative responsibilities of the laboratory directors, the individual researchers, and the
headquarters ORD staff have become blurred. Similarly the roles of issue planner,
laboratory director, and administrator in headquarters ORD are now in conflict or, at a
minimum, present areas of overlapping responsibility. Also raised as an issue was the
performance of administrative management versus research management.
Locus of control issues for the program office laboratories were limited, because the
programs exercise direct control of their laboratories. Study participants reported instances
where the expectations of the program exceeded the resources provided. The suggested
remedy to this problem was either increased administrative representation for the
laboratories within the program office or organizational changes within the program office
to place the laboratory function under the same administrative chain of command as the
portion of the program office requiring the laboratory's support.
The major problem in this area for the ESOs is that the resources for supporting
personnel come from the regional-level programs and not from a central office. The
absence of a central office is central to the issue of ESOs representation at the
headquarters level. Many of the participants in the study voiced concerns that ESOs, and
in particular the ESO laboratories, do not have representation equal to that of other
programs at the headquarters level. While the program offices at the regional level are
represented by the AA for their program, and the ORD laboratories are represented by the
AA for ORD, ESOs do not have a similar AA-level representative. Creation of an AA for
ESOs would resolve this issue but this solution raises another issue. In response to
specific questions on this issue, study participants raised the following concerns:
5-10
-------
The separation of ESOs into a separate AA-ship would result in the creation of
an additional administrative layer.
• The ESOs would be separated from their customers in the regions.
• A separate AA would run counter to the concepts of streamlining and multimedia
activities.
Another locus of control issue raised by the ESO participants in the study involves
applied research directly related to implementation of EPA's programs. Methods and
procedures developed through ORD and at headquarters EPA are used in the regions. As
customers for these items, ESO staff members would like more applied research done at
the regional level by individuals who are either the users of the products or are in direct
contact with the users.
Universal among the participants was the issue of selection and prioritizing of research
projects to be performed. This issue was also reflected in the degree of satisfaction felt by
the implementing programs with the existing work planning process. The issue of who
controls the selection of research projects raises the issues of prioritization of projects, the
existing process for prioritization (issue-based planning in ORD), and division between
fundamental research and research to support program implementation. The tension related
to these issues is particularly intense when there is disagreement over an organization's
primary customer. The prime example of this is difficulties with focusing ORD's work on
either fundamental research to benefit science in general and the needs of the program
offices for applied research to support program implementation.
In addition to these conflicts within EPA, external customers, and especially the
Congress, also come into play. These conflicts manifest through congressional mandates
and deadlines, direct appropriations for specific work, and requests for specific actions
from politicians, organizations, and individual citizens. All these requests raise the issues
of degree of control over the individuals and infrastructure available to conduct work.
5.2.4 Administrative Impediments
Facilities and equipment issues for the ORD laboratories vary with the location. A
portion the activities of the ORD laboratories are tied to their locations by resources or
constructed facilities that cannot be moved or would be difficult to move. Any discussion
of movement of the portion of the ORD work tied to these resources raises the issue of
loss of the capability or payment of large replacement costs.
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Facilities and equipment problems are not evenly distributed among the program office
laboratories. In general, the program office laboratories have a lower level of access to
funding for new equipment, and limitations on funding prevent the accumulation of
resources to purchase the larger, more expensive items over multiple funding periods.
Many of the participants raised issues related to impediments to their work. These
issues start with the basics of facilities and equipment. Beginning with the ESOs
laboratories, three regions have facilities constructed within the past three years that are
sufficient for their current and anticipated future needs. Three additional regions have
facilities that, while not new, are sufficient at least for current needs. The remaining four
regions have either contracted for or are actively pursuing new laboratory facilities to
replace existing facilities that are inadequate for current needs. In the area of equipment,
the study has shown through laboratory visits and interviews that the ESOs have sufficient
equipment to perform their tasks and that the current system of budget allocation for the
purchase equipment is sufficient. However, obtaining routine supplies and maintenance
was cited as an increasing problem.
Human resources was raised as an issue at every ESO. Human resources appear to be
the limiting factor at the ESOs. The annual effort to obtain resources from the regional
program offices differs in degree from region to region, but the lack of a stable core set of
resources was mentioned during interviews in every ESO. Many of the ESOs also cited
resource "underpayment" for services performed for regional program offices. At the same
time, the regional customers who provide these resources support the existing system by
which they "pay" with FTEs for work performed by ESOs. The greatest flaw in this
system found during the study is the lack of accurate pricing factors that are truly
representative of the cost in both FTE and dollars of work conducted by ESOs for the
regional program offices. One of the ESO divisions does maintain a tracking and pricing
system, indicating that implementation of such a system is possible. Such a system is a
fundamental requirement for realistic determination of the most efficient way to provide
ESOs. Such a system would also alleviate claims both by ESOs and regional customers
about the expense and/or underpayment for services performed. It should be noted that the
need for accurate pricing factors is not limited to the ESOs. All of the laboratories need to
have accurate costing, accounting and accountability systems Agency-wide information
that are a part of management systems. Such systems would enable EPA to improve its
planning, programming, budgeting and accounting.
Additional resource issues include a lack of resources to support the activities of the
criminal and civil investigators operating within the regional offices. Until now, the
investigators efforts have been supported by taking resources from the various program
offices. As the numbers of civil and criminal investigators continues to rapidly increase in
response to the Pollution Prosecution Act, this method becomes less and less viable.
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Another resource available within the regions for accomplishment of ESOs tasks is the
use of contractors. The primary issues raised on the use of contractors were the resource
intensive nature of the process for obtaining, communicating with, and performing
oversight for Environmental Sampling and Analysis Team (ESAT) contractors within the
ESOs. Multiple respondents stated that this work could be performed more efficiently by
federal personnel. The constraints on communication and direction of these contractors, as
well as the requirements for oversight, have the effect of making these contractors
increasingly uncompetitive in terms of cost-per-sample analyzed or task performed. The
impact of contract management duties, the convoluted communication chain, and the
duplication of management hierarchies required under current contracting procedures in
EPA were all named as items that divert work resources from the actual performance of
laboratory work. Both ESO and ORD participants reiterated the potential efficiency of
using EPA as opposed to contract employees to perform laboratory work.
In ORD, budgeting difficulties are complicated because the budgets for activities
frequently are not known until midway through the fiscal year. Even when budgets are
known they are not stable from year to year. This instability leads to difficulties in
planning and execution of multiyear projects.
Even when outside resources are available, either from states, other federal agencies,
other regional offices, or national EPA programs, respondents have stated that the existing
budgeting structure is inflexible, making it difficult or impossible to incorporate these
resources into regional ESOs. The existing system also prevents the joint funding of
training and services with state and tribal agencies even when this would result in a cost
savings to the federal government.
A potential solution to the problems of dealing with contractors and with the budget
structure was suggested at several ORD laboratories—conversion of the laboratory to a
Federally Funded Research and Development Center (FFRDC) or government-owned,
contractor-operated (GOCO) organization. These alternative accountability models are
discussed in Section 10, where the conclusion reached is that the problems that the
conversion would solve are amenable to solution with less disruptive measures.
5.3 SUMMARY OF ISSUES
Laboratory visits and customer interviews identified issues that could be resolved
using the options discussed in Section 7 and throughout the remainder of this report. The
following summary issues is to be carried forward into the options analysis. Not all issues
apply equally to all three portions of the EPA system analyzed in this document.
Therefore, separate issue lists have been prepared for the ORD laboratories, the program
office laboratories, and the ESOs.
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5.3.1 ORD Laboratory Summary Issues
Mission Focus
Short-term versus long-term research
Selection of primary customer (EPA programs versus "science")
Expectations
• Research and technical support for regulatory program implementation
• Research to support policy and rule making
• Information on basic and emerging environmental issues
• Support for unanticipated demands
Locus of Control
• Selection of research projects to be performed
- Prioritization of projects
— Existing process for prioritization
— Division between fundamental and applied research
• External customer impact (Congress/politicians-public requests)
• Control of laboratory administration and budgets
• Conflict of interest in issue planning
Administrative Impediments
• Lack of resources/infrastructure to maintain world class science
• Construction of new facilities
• Burden attached to management and use of contractors
• Color of money issues
• Restrictions on non-ORD funding
• Negative impact of competitive cooperative agreements
• Information management systems not common to other parts of Agency
5.3.2 Program Office Laboratory Summary Issues
Mission Focus
• Division of research between program office laboratories and ORD laboratories
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Expectations
• Priority will be given to tasks assigned by program office
Locus of Control
• Resources provided are less than needed to support expectations
• Appropriate chain of command within program office
Administrative Impediments
• Difficulties in procurement of equipment, supplies and maintenance
• Equipment budgets/funding for equipment (including restrictions on accumulating
funds)
• Color of money issues
Timing of budget availability
• Information management systems not common to other parts of Agency
5.3.3 ESO Summary Issues
Mission Focus
• Efficient provision of laboratory services (routine and special)
• QA/QC conflict-of-interest within regional structure
• Appropriate location for field monitoring within regional structure
Expectations
• Rapid gathering of environmental information on unplanned events impacting the
public
• Close technical support for regional, state, and Native American programs and
the regulated community
• Support in special and emerging areas of laboratory support combined with
uneven demand
Locus of Control
• Representation of ESOs at the headquarters level
• Performance of applied research at level closest to users
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Administrative Impediments
• Construction of new facilities
• True cost of ESOs
• Support for civil/criminal investigations
• Budget flexibility for external/joint funding
• Burden attached to management and use of contractors
• Limitations on human resources
• Information management systems not common to other parts of Agency
5.4 STATE LABORATORIES
This chapter is based on interviews conducted with state environmental personnel in
California, Delaware, Florida, Georgia, New Jersey, Oklahoma, and Pennsylvania. The
views held by the states depend to some extent on the EPA region to which they are
attached. Furthermore, it appears that there may be considerable variations in the level of
support provided by the regions; the conclusions in this chapter could be affected by the
lack of input from states in other regions.
The states in each EPA region depend both directly and indirectly on the EPA. For
example, the EPA is the originator of many of the laws, regulations, and rules that the
states either must meet or themselves impose upon others. Because of the usually greater
resources and expertise of the EPA, the states look to EPA for both legal and technical
guidance.
Most states have an environmental enforcement unit, often organized analogously to
the EPA. The state enforcement unit usually has a laboratory providing a range of analytic
and technical services in support of the environmental regulatory activity. Due to this
parallel organization, both regulatory and laboratory state staff have substantial contact
with their EPA counterparts.
Because the states vary widely in the breadth and intensity of their environmental
regulation activity, it is not possible to provide a complete list of the types or extent of
service interactions between the states and the EPA. However, visits with a sampling of
states showed that the laboratory services received by the states include the following:
• Consultation on analytic procedures and problems
• Source of analytic service for unusual types of measurement
• Training in administering new programs and regulations
• Joint work with EPA on toxicity and other research studies
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• Audits of state labs by EPA
• Reviews of state regulatory programs by EPA
EPA assistance in stimulating state-state cooperation
• Assistance with enforcement actions
• Staff training
• Source of performance evaluation samples for use in state certification of
commercial labs
The small number of states interviewed in this study does not provide a complete
picture of the satisfaction of the states with the EPA services. Nevertheless, several
common themes emerged during the interviews:
• The states generally felt well supported by the ESOs, but had less contact with
the ORD and program office laboratories. Some states perceived a lack of
awareness within the ESOs of work being performed at ORD and program office
laboratories. This has led to an inability to provide the desired support for state
air and radiation analytical requirements.
• Several states suggested that the ESOs should make less use of contractors. They
believe that regional personnel are burdened by contract management
responsibilities and have lost technical capabilities as a result.
• The states wish to see more program and analytical training services. Region 3
administers a cooperative training program for the states that could serve as a
model for other regions.
• Because states have little travel money (especially for out of state), the closer the
geographic proximity, the stronger the relations with the EPA laboratory.
• The state staff value long-term, trusting personal contacts as a key to close
working relationships.
• Several states suggested increased involvement of ESOs and state laboratories in
long-term planning for analytical capabilities, especially for higher-cost, less-
frequently used capabilities.
The state laboratories are frustrated by regulations that specify different methods
to do essentially the same analysis for different EPA programs and by the
slowness of those regulations to incorporate improved technology, such as the
use of inductively coupled plasma-mass spectrometry (ICP-MS) instruments.
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• Several state officials expressed the opinion that there is not enough
communication between EPA programs and analytical services technical staff,
especially between those who obtain or analyze environmental samples. One
result of this lack of communication is the profusion of and slowness to
incorporate improved technology in analytical methods noted above. State
officials felt that the technical role in formulating regulations concerning
analytical methods should be equal to the roles played by regulatory and legal
concerns. Several states suggested that a single administrative entity for
analytical services could serve raise the level of technical input and improve
communication.
In summary, the EPA laboratories can and do provide services to the states that are
highly valued. However, the states strongly wish to retain the existing geographic
proximity to the EPA laboratories. The states strongly desire that EPA provide adequate
resources for support of the state programs.
5.5 PRIVATE SECTOR ORGANIZATIONS
Three organizations, E.I. du Pont de Nemours and Company, Ford Motor Company,
and the Westhollow Research Center (WRC) of Shell Development Company, have been
visited by MITRE. These are multinational corporations with a diversity of product lines
within their given industrial sectors of chemicals, motor vehicles, and oil. All are subject
to environmental regulations in their operations as well as in the characteristics and use of
their products, and thus a significant portion of their R&D efforts are expended to comply
with EPA requirements. Most of these observations are common to all the organizations
that were visited; exceptions will be noted.
• At Dupont and Ford, R&D is a distributed function with laboratories located at
or in close proximity to internal customers (strategic business units or
equivalent). However, Shell has consolidated this function at WRC.
• Dupont and Ford perceive that their distributed structure and locations focus
needed resources and priorities on near-term requirements of the business units.
Provide technology to support and renew existing businesses
Identify and define new businesses within the sector
In contrast, in 1976 Shell determined to consolidate its research laboratories in
order to improve efficiency and effectiveness.
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Only three years would be required to pay off relocation expenses through
efficiency gains.
The ability to recruit and support world-class experts by pooling costs
would improve effectiveness.
• Central research is a corporate function for science and technology
Provides basic knowledge for existing businesses
Develops the technical base for new businesses
• Responsibility for all R&D functions is vested in a single corporate executive
reporting to the chief executive officer.
• Common technical support elements, such as analytical services and information
systems, report to a single manager.
• All research and technical development staff share a common understanding of
the corporate mission and goals while retaining their professional integrity.
• Internal transfer of scientific knowledge and technology is promoted through a
variety of means, including program planning, informal and formal networks, and
internal publications.
• Strategic and annual planning establish needs, define resource requirements, and
set priorities.
• Annual R&D budgets are approved by the Board of Directors.
• Researchers from central research seek the opportunity to and willingly
participate in project teams formed to address near-term problems.
• Ample budgets are provided for professional development and related
professional activities.
Most, if not all, of these principles and practices could be incorporated by EPA into its
laboratory operations.
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SECTION 6
MANAGEMENT IMPROVEMENTS
Improvements in quality, efficiency, and effectiveness can be gained through improved
management policies and procedures regardless of the organizational structure that is
adopted. In Section 5 of this report, a number of issues that were identified during the
course of the study were presented. Some of these relate to current management practices
that are perceived to reduce the quality, efficiency, or effectiveness of EPA's current
laboratory operations. These issues have been examined by MITRE within the current
structure, and suggestions for improvements are made below under broad categories that
are applicable to current conditions as well as any of the proposed structural options.
6.1 QUALITY ASSURANCE
In partial response to one of the major recommendations in the report "Safeguarding
the Future: Credible Science, Credible Decisions" (Expert Panel on the Role of Science at
EPA, March 1992), that QA and peer review should be applied to the planning and results
of all scientific and technological efforts to obtain data used for guidance and decisions at
EPA, including such efforts in the program offices and ESOs, the Administrator issued a
peer review policy to be implemented Agency-wide. Although all of EPA's laboratories
have some form of a review process, it should be noted that the formal QA/QC
responsibilities are not generally given high visibility in EPA, even in ORD where the
Director of the Quality Assurance Management Staff reports to the Office of Modeling,
Monitoring Systems and Quality Assurance, which reports to the AA for R&D.
To improve QA in the performance and use of science and technology throughout
EPA, an in-depth review of the existing process should be made, particularly with the
objective of achieving end-to-end QA throughout all of EPA's activities. The question of
whether the QA functions should report to the Administrator/Deputy Administrator should
also be addressed.
6.2 MISSION CLARIFICATION
To achieve improvements in the quality, efficiency, and effectiveness of EPA's
laboratories, it is essential to develop an agreed-upon statement of the mission of the
Agency and to implement a top-down strategy for the laboratory operations in support of
it. Such a strategy must address such issues as:
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Regulation versus science roles
Long-term research versus short-term technical support needs
Exploratory research versus monitoring and compliance
Media versus integrated approaches to scientific and technological issues
In a joint letter (February 1994), the laboratory directors have recommended dividing
the research program into three components: (1) strategic research, (2) regulatory support
to include technical assistance, and (3) national cross-cutting programs (such as EMAP).
They emphasize that strategic research cannot and should not be separated arbitrarily from
regulatory support research at the implementation level. And further, they recommend
against percentage allocations to the various categories of research.
Although current activities and their quality have been documented, in this study the
question of what should be done and how well the current laboratory structure fulfilling
the strategy and its requirements has not been addressed. Examination and clarification of
the Agency's mission would be helpful to management and staff.
6.3 PLANNING AND PRIORITY-SETTING
Section 5 of this report summarizes the observations from the laboratory interviews of
the expectations that the customers have of the content, timeliness, and quality of the
products and services of the laboratories. To a great extent, the lack of, or perceived lack
of, responsiveness to customer needs depends directly upon the mission of the individual
laboratories and the priorities that have been assigned to their work. If the mission
clarification described above is accomplished, the base for planning and priority setting
will be established that should lead to a common set of expectations. The issue-based
planning, with improvements in its scope and participants, can serve as a point of
departure for development of a framework to be employed for achieving the objective.
6.4 DELEGATION OF AUTHORITY
There appear to different practices (and perhaps policies) with regard to the delegation
of authority to the laboratory directors. Where the authority at the laboratory level is
limited, the efficiency of the operation may be impaired. More detailed examination of
policies and procedures could lead to the elimination of perceived problems such as the
inability to employ funding where it is most needed and the inability to respond in a
timely manner due to a long approval chain.
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6.5 IMPEDIMENTS TO LABORATORY PRODUCTIVITY
The bulk of comments MITRE recorded in its extensive interviews with laboratory
managers and staff reflect serious frustration with administrative impediments to getting
the research job done properly. It was apparent that most personnel feel a strong desire to
fulfill their obligations to EPA, the public, and the scientific community, but feel just as
strongly that unnecessary bureaucratic policies and procedures stand in their way. We
found relatively little interest in global options such as reorganizing the laboratories, but
intense concern that whatever option are pursued, these administrative impediments will
be eliminated.
In this section, those impediments most commonly cited in the interviews are
described. Then, approaches to eliminating these impediments, either directly, through ad
hoc executive or legislative action, or systematically, by changing some "ground rules" of
laboratory management, such that certain of the impediments are rendered moot are
described.
With few exceptions, the interviewees described a frustrating "Catch 22" situation in
which they are expected to accomplish at least as much research and program support as
ever, but without the qualified personnel, either federal or extramural, necessary to
succeed. They contend that federal staffing is inadequate to meet the needs, and that the
level of competence can be expected to decline even faster than the numbers of federal
scientists, as retirements remove senior personnel over the next several years and leave
fewer, less experienced, and less-respected young colleagues. Further, recent restrictions
on the use of contractors and cooperative agreements have rendered it very difficult and
sometimes impractical to obtain needed scientific support through extramural channels. In
summary, the work still has to be done, but all avenues to obtaining personnel resources
are increasingly restricted.
This is a pervasive issue, affecting the answers to other important questions like the
adequacy of facilities and equipment, ability to hire desirable staff, timeliness and quality
of scientific support, opportunities for recognition, and even more fundamentally, the roles
that EPA laboratories can hope to fulfill in the future. Clearly, some strategy must be
found to bring the human resources available to do the job into line with workload and
quality expectations.
Four basic strategies, or combinations of these, are available to EPA in seeking to
remedy this problem: increase federal FTEs, increase the accessibility of high-quality
extramural labor, increase the efficiency of both federal and extramural efforts, or reduce
the expectations placed on the laboratories.
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Increasing federal FTEs in the laboratories is the intent of "contractor conversion," and
any new FTEs that are allocated down to the laboratories will be gratefully received.
However, they are, by definition, replacements for the on-site contractors that formerly
supported the programs and will not fully replace the losses from contract terminations.
However, as a rule, interviewees stated that federal employees are worth much more to
the laboratories than an equivalent number of contractor personnel, owing to the
restrictive rules governing use and direction of contractors. Other than slight
augmentations from contractor conversion, laboratory staff expect the numbers and grades
of authorized personnel to decline continuously into the future.
It was noted in the ORD interviews that, in many cases, the net effect of hiring
freezes and past efforts to attract senior scientists has left a wide gap beneath the senior
scientists, such that there is an inadequate structure of junior scientists and technicians to
support the work of the senior scientists. In some individual laboratories, lack of grade
stratification is expected to result in complete loss of some research areas upon retirement
of their practitioners and inhibits the development of cost-effective research teams by
placing work with the lowest appropriate grade for each type.
Accessibility to high-quality extramural support has declined drastically within ORD
laboratories as a result of Agency concerns about appropriate use of contractors and
cooperators. The ESOs are less affected, because of the routine nature of contract services
they require, but the program office laboratories may expect increasing difficulties. Until
recently, the ORD laboratories have dealt with the deleterious effect of FTE limits and
hiring freezes by shifting major scientific and engineering roles to highly qualified
contractors, who were, for practical purposes, collocated with EPA and served as extended
staff. In addition, long-term, stable working relationships were maintained with university
and institutional researchers through cooperative agreements, and these cooperative
agreements were used, in many cases, to obtain information needed to conduct the
business of the Agency.
Both of these extramural arrangements were susceptible to abuse. Federal regulations
and contract law enforce an arms-length relationship between federal technical personnel
and contractor staff, in order to avoid (1) improper supervision of contractor personnel as
staff extension; and (2) unauthorized redirection of contractor efforts, with attendant cost
implications. Regulations governing the use of cooperative agreements are intended to
foster joint scientific and technological efforts, but may not be used to procure services or
goods hi a quid pro quo arrangement, where contracts are appropriate.
Evidently, federal auditors found sufficient cause in their recent reviews of ORD
laboratory extramural practices to stimulate a stringent reinforcement of proper rules and
procedures. However, it appears that the interpretation of these intentions at the laboratory
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level may have been an overreaction. This subject was raised during the interviews as an
impediment to the efficient conduct of laboratory operations, especially when the policies
governing contractor management prohibited the intramural staff from working in the
same laboratories as extramural staff and when it inhibited the giving of directions to the
support staff during the conduct of experiments and sample analysis. Such an
interpretation would seem to be far more strict and constraining than is seen elsewhere in
the federal government. It is inconsistent with the use of contractors to support R&D,
since it frequently is impracticable to specify methods and outcomes with any real
precision where original R&D is desired—if the answer were known, there would be no
need for the contract effort.
Similarly with the use of cooperative agreements—the interpretations now applied at
the laboratories are uniquely strict and appear to be excessive. (This is not to suggest that
EPA contracting officials have misunderstood the regulations, but rather that less qualified
personnel elsewhere in the system have interpreted their directives freely.) ORD
personnel have been led to understand that cooperative agreements cannot be used where
any benefit may accrue to EPA from the mutual work arrangement. However, the exact
purpose of cooperative agreements is to provide for shared work efforts where the
government has an expectation to participate substantively and to accrue a share of the
benefit from this effort. Instead, ORD staff contend they have been instructed to regard
cooperative agreements exactly like grants—transfers of money with no expectation of
shared benefit. Under this interpretation, the second vehicle to obtain extramural technical
help is foreclosed.
A universally cited contributor to problems using contractors is the excessive time
required to originate and implement an agreement. Six or more months was frequently
mentioned as an optimistic average time to put a contract against a need. Since EPA has
greatly reduced the availability of general-purpose on-site contractor support for quick-
turnaround support, many short-term Agency needs cannot be addressed with extramural
resources. This is further exacerbated by excessive delays in allocation of funding to
laboratory programs—normally, five to six months of each fiscal year pass before funding
levels settle down at the working level, at which time, there is hardly time to begin and
complete the lengthy contracting process within the term of the fiscal year.
The third avenue available to EPA to bring laboratory workloads into line with
personnel resources is to increase the efficiency of each labor hour expended. It is likely
that every option discussed in this report bears in some ways on the efficiency of
laboratory staff. However, the interviewees focused on several key administrative
impediments that diminish their efficiency, as discussed below.
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Most commonly, laboratory personnel complained that an excessive portion of their
time is consumed in contract management. Some individuals in ORD and program office
laboratories stated that most of their time is used this way, despite job descriptions as
bench scientists, and that any research they perform is done after hours. Little or no
support is provided to them in performing the more routine contract management tasks,
and more time is consumed in those tasks than in providing professional review of
contractor products.
Laboratory productivity is unpaired by what were said to be three- to six-month delays
in routine purchases of non-capital equipment, services, and supplies. Such delays are
crippling and demoralizing in an R&D environment, where needs cannot always be
anticipated.
Scientific productivity is impaired by a widely remarked lack of travel funds. Travel
funds have been reduced in recent budgets, and official priorities for their use have
favored managerial purposes rather than scientific purposes. Consequently, research staff
at several laboratories report they are unable to work collaboratively with their peers and,
further, are discouraged from submitting papers for publication by the knowledge they
will not be funded to present them at conferences. This presents a frustrating contrast with
the goal of the Agency to support first-rate science and to earn the respect of the scientific
community for its scientific accomplishments.
The ORD laboratories face an unusual funding difficulty associated with the issue-
based planning process. That process addresses research needs that are identifiable well in
advance—the sort of R&D tasks that most outsiders associate with the ORD laboratories.
However, it does not provide explicitly for unforeseen requirements that arise at
Headquarters level from week to week, requiring scientific consultation and sometimes
developmental effort. Depending on the laboratory, such short-fuse requirements can
represent a major drain on senior management and scientist talents. This reduces
laboratory productivity in respect to the explicit assignments they have received through
issue-based planning and might be said to distort the intentions of budget planners.
To maintain and improve productivity it is essential to measure it in some way.
Currently, the laboratories lack an accounting system that permits routine assignment of
all costs to each activity. It is, for example, not routinely possible to say how much it
cost, including the cost of federal staff effort, to complete a short-term assignment for
Headquarters. Certain of the ESO laboratories are close on this, especially where the more
routine services are concerned, but the rest cannot meet this need.
A final strategy available to EPA to match workload requirements to personnel
resources is to alter or reduce the workload expected of laboratories. If personnel and
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other resources cannot be provided in adequate quantity to excel in performance of the
entire current mission of each type laboratory, then it is better to reduce demands than to
tolerate deterioration of performance across the board.
Consideration of this strategy goes quickly to the heart of cherished beliefs about the
role of laboratories in the Agency. For example, a substantial proportion of senior
scientists at ORD laboratories contended that the real "customer" for their research is the
scientific community at large, rather than the program offices funding the work. It is
possible, in contrast, to argue that all EPA laboratories should be limited to applied
research and analysis, in clear and direct support of the regulatory functions of the
Agency, and that basic research of the sort that responds to the scientific community as its
customer belongs in the universities and research institutes of the nation. Another
cherished belief regards the extent of "inherently governmental" laboratory functions—it is
not at all certain that most analytical operations now performed by government FTEs in
ESOs could not be contracted out—even those in support of litigation. In any case,
serious consideration of reducing the workload expectation on EPA laboratories would
necessarily include such categorical options.
6.6 MANAGEMENT IMPROVEMENTS IN RESPONSE TO IMPEDIMENTS
6.6.1 Ad Hoc Responses
Each of these administrative impediments to laboratory productivity can be addressed
and significantly ameliorated by vigorous executive action, although some logical
approaches would require White House and Congressional concurrence. Ad hoc response
to each impediment is somewhat haphazard, of course, and would certainly produce
uneven success, but a consistent effort would eventually address most problems. System-
wide approaches are discussed in the next section.
The continuing erosion of FTE authorizations through the combined workings of
Agency policies and retirements ought to be acknowledged, and specific strategies created
laboratory by laboratory to evolve a work force of balanced grade distribution over the
long run. This will promote cost-effectiveness by providing lower grade staff to perform
less demanding parts of the work, and will foster a succession of new scientists who can
be mentored by and continue the work of today's senior scientific staff. Contractor
conversions should be allocated by Headquarters and the laboratory directors with this
long-term purpose in mind.
Among the first new hires or reassignments within the ORD and Program Office
laboratories ought to be a new cadre of contract support specialists, who would be
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assigned directly to those senior scientists who originate and manage contracts and
cooperative agreements. These contract support specialists would relieve the non-scientific
load on senior scientists of managing extramural agreements.
A review of EPA contracting is currently being conducted by NAPA; it is to be
completed on 15 June 1994. Implementation of the results of this study may both alleviate
many of the current problems in R&D contract acquisition and clarify the issue of
inherently government functions as apply to the use of R&D contractors. The issue of
personal services should be reviewed to determine if current policies either are too strict
as they relate to laboratory operations or if they are being misinterpreted by laboratory
management. The Agency should undertake to educate its contracting staffs at all levels
and all technical staff responsible for contract and cooperative agreement management, so
that the closest practicable working relationships with outside support can be maintained
without confusion or fear.
A program should be devised and implemented to streamline the development of new
contracts, with the goals of (1) reducing the burden of contract origination on staff
scientists, and (2) reducing the time requirement 50 percent from current delays. A
parallel program should be devised to improve the ease and speed of purchasing items of
any cost below the $50,000 limit.
The bench-level allocation of budget should be settled and communicated to
implementing staff not later than 31 December of each new fiscal year. That allocation of
budget ought to be protected against reallocation from above except in the most extreme
of emergency requirements.
Travel funds for the explicit purposes of scientific collaboration and the presentation
of peer-reviewed papers at scientific gatherings should be increased radically, by
reallocation of funds from administrative purposes and from Headquarters organizations,
and by alteration of the current prioritization of travel funding. The amount of such
increase and the sources will require a small study to develop alternative estimates, and an
executive decision to implement.
ORD and the program offices must obtain reliable average estimate of the real costs to
their laboratories of unplanned, unfunded requirements, and commit funds annually
against that estimate. Only in this way can the true devotion of resources to planned
functions be determined, and the response to unplanned needs appropriately staffed and
provided for.
A corollary of this is that the Agency must develop as quickly as possible, in stages if
necessary, an accounting system that references all forms of cost, including depreciation,
6-8
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to projects and other activities of the laboratories. With this accounting system, it will be
possible in the future to assign the full costs of supporting activities to each customer of
the laboratory, and to examine and minimize the costs of administration and reporting. It
will be far easier to decide which laboratories are most cost-effective to retain, and which,
perhaps, are relatively costly to maintain. Without such a system, such analysis will be
locked in the realm of opinion.
6.6.2 Systematic Responses
As discussed above, various ad hoc responses to these administrative impediments are
possible, but these are inevitably scattered and uncertain of success. Two more systematic
approaches are deserving of consideration: empowerment of laboratory directors and,
building on that, a market-based approach to implementation.
The empowerment of lower levels in organizational hierarchies is a leading tenet of
reinvention and has been featured in the Streamlining Report as a critical element of its
implementation. Empowerment of laboratory directors to control all feasible aspects of
their organizations could permit them to address several of the impediments discussed
above. In most cases, this empowerment implies major changes in the current policies and
practices, within the Agency and even by Congress. However, if the Laboratory Directors
could be granted new control of personnel resources, they could gradually cause their
laboratories to evolve toward a balanced skill and grade structure appropriate to each
work program and the needs of their customers. They could provide for contract support
specialists in support of senior scientists, if they judged the need significant. Acting alone,
or in cooperation with other laboratories, they could develop the accounting structures that
would permit them to focus productivity improvements and cost reductions.
Over time, empowerment of the laboratory directors to mold their organizations will
lead to a laboratory system much more finely tuned to the needs of "paying customers"
Where laboratory capabilities overlap, there naturally would develop a competition among
laboratories to provide services to the customers at least cost for best quality.
This observation suggests a very different approach to implementing management
improvements in the laboratories and, ultimately, to dealing with perennial questions like
responsiveness to customers and the relative roles of basic and applied research. This
approach is founded on the Streamlining Study and the laboratory director's response to
that study. It differs by proposing methods of implementation based on market forces
rather than command-and-control, top-down decision making. It was suggested by
MITRE's informal observation that the happiest laboratory and customer relations are seen
where program managers maintain direct and constant contact with the laboratories they
6-9
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are funding to meet their needs, and the laboratories, in turn, interact with the program
managers as their direct customers.
This approach begins with the current laboratories and encourages evolution, through
market forces, toward the most efficient complement of laboratory service providers. To
accomplish this, EPA would provide mechanisms to create a market in laboratory services
of all types (except for a narrow category of reserved government functions). It would
define customers for laboratory services and provide channels for those customers to
publicize their needs to the laboratory community. EPA would empower the Laboratory
Directors to assemble project teams and research plans to meet those needs, drawing
resources from their laboratories, other laboratories in consortia, and extramural resources.
This approach is founded on the principles of market economics, modified where
necessary to preserve crucial EPA functions. All other approaches considered here are
fundamentally prescriptive; that is, they attempt to prescribe the most effective allocation
of laboratory resources to Agency needs based on a central theme. This approach takes as
its starting point that data and debate alone cannot resolve the differences of opinion that
arise when such allocations are attempted and presupposes that any new approach based
on the same prescriptive philosophy will fail to end the debate. Further, this approach
argues that no group is sufficiently wise and knowledgeable to "pick the winners and
losers" for today and the future. Instead, it seeks to harness familiar market forces in a
long-term evolutionary process, through which the "winners" in providing laboratory
services of all types to meet Agency needs will emerge naturally, by providing the most
cost-effective suite of services to their direct customers.
To make this approach operational, it would be necessary to create a modified free
market in laboratory services, in which customers are free to define and advertise their
needs, and suppliers are empowered to propose meeting them by reasonable strategies.
Six major organizational functions must be recognized and implemented, as follows:
• Customers must be empowered to communicate their needs and to provide all
needed resources to the selected source of services.
• Laboratories must be empowered, through changes in authorities, administration,
and accounting methods, to respond to customers' requests for proposals, to
assemble appropriate intramural and extramural teams, and to manage the
execution of projects independently.
6-10
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• A "marketplace" must be created in which buyers and sellers of laboratory
services can get together—appropriate means of direct two-way communication
must be provided.
• Adequate controls and planning structures must be instituted to guarantee that a
minimal list of essential EPA laboratory services is preserved, whatever the
possible workings of the free market.
• Exploratory research, which may not be sought by any one program, must be
protected from short- and medium-term market pressures. Laboratories may
perform exploratory research, but for a separate client, perhaps an expanded
Office of Exploratory Research.
• A long-term R&D surveillance function must be created, to monitor and modify
the elements of this approach as experience is gained with its impacts.
Impediments to this approach include the current large organizational investment in
headquarters functions, staff, accounting structures, and annual planning structures that
have arisen under the current command-and-control approach. Certain of these
impediments can be changed by the Administrator; other critical impediments may require
supporting Congressional action.
The market-based approach toward research management has worked for the General
Electric Company (GE) (Center for Strategic and International Studies, September 1993).
Until the late 1980s, GE's R&D Center received two-thirds of its funding from
assessments of GE businesses, who complained that R&D efforts were not focused
sufficiently on their needs. In 1988, GE shifted the balance of R&D Center funding to a
75/25 formula, under which 75 percent of funding comes from direct contracts with the
GE businesses and 25 percent from assessments. The 25 percent number was selected on
the strength of data indicating that about 18 percent of R&D Center activity in the past
has been fundamental research that might not find a direct client in the market-based
approach. GE has observed much greater interaction between the R&D Center scientists
and the GE companies and much improved satisfaction among the GE companies with the
performance of the R&D Center.
In conclusion, a number of serious administrative impediments to the cost-effective
execution of laboratory programs have been identified that apply in most cases to the
ORD and program office laboratories and the ESOs. Given sufficient management concern
and commitment, both ad hoc and systematic approaches can be pursued to reduce these
impediments.
6-11
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SECTION 7
STRUCTURE FOR ANALYSIS OF OPTIONS
7.1 INTRODUCTION
EPA was charged by the Senate Committee on Appropriations to explore whether a
consolidated laboratory structure would better enable the Agency to accommodate the
need for integrated research and monitoring. In this chapter the structure for the analysis
of the options is presented. Major options posed by the Steering Committee are defined in
sufficient detail to permit an analysis to be made of the advantages and disadvantages of
restructuring or realigning EPA's laboratory complex and instituting changes in operating
practices and the options are related to the laboratory missions discussed in Section 4. The
criteria that are used to evaluate these options are also defined.
7.2 OPTION DESCRIPTION
The options for realignment are defined based upon the previous Agency studies (as
discussed in Section 3), recently published reports, and discussions with numerous
individuals throughout EPA and other organizations. Options are defined at a division (or
equivalent) level or above in the existing laboratories for the purpose of clarifying the
description of the option rather than dealing with restructuring as an abstract concept.
Other realignments within a given concept are also possible and no attempt has been
made to select an optimum configuration for any concept. Confining the focus to the
higher-level organizational units allows the analysis and comparison of options to be
performed at a level that clearly discriminates the advantages and disadvantages of each in
comparison to the existing structure. The final decision on realignment of the laboratories
rests with EPA management.
For the purpose of clarifying and separating the issues, only the five structural options
are discussed in this section:
• Customer Orientation: focus on program offices as the users of science and
technology
• Streamlining: reduce administrative layers
• Carnegie Commission: emphasize multimedia issues in ORD
7-1
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Distinct Environmental Services Organization (DESO): centralize
responsibility for all technical support functions of regional ESOs and program
offices
Geographic Location: address location-specific environmental issues
Management Improvements, which would apply to all structural options, were discussed
in Section 6.
The option descriptions begin with a general description of the option, followed by
any additional assumptions that were made for purposes of evaluating the options.
Additional variations could be made in the assumptions. As discussed in Section 1.2, three
types of consolidation—organizational, functional, and physical—are possible. While
organizational and functional consolidation are integral to the options, actual physical
consolidation is not. Therefore, for all the options, two versions were considered, one
without and one with physical consolidation.
7.2.1 Baseline
The Baseline, the current laboratory structure frozen in time, is described in detail in
Chapter 4 and Appendix A and shown in Figure 7-1. This is the standard against which
the structural options are compared. It can be characterized as a distributed or
decentralized structure with the 39 laboratories ultimately reporting to six AAs and ten
Regional Administrators. The underlying organization principle is to separate the scientific
and technological functions into research and development activities that report to the AA
for Research and Development and to align development, technical services, and support
activities by environmental medium or major function, such as enforcement. The intent is
to distribute and control the scientific and technological resources at the most relevant
point of application. Resource distribution (by FTEs and dollars) by policy level is
presented in Table 7-1. No single individual (other than the Administrator/Deputy
Administrator) is responsible for all of the scientific and technological functions of the
Agency. The only explicitly identified quality assurance function in EPA is the Director of
the Quality Assurance Management Staff, who reports to the Office of Modeling,
Monitoring Systems and Quality Assurance under the AA for Research and Development.
The Science Advisor has cognizance of all scientific and technological functions,
including quality assurance, and acts as an advisor to the Administrator. The current
structure has been in effect since 1979.
7-2
-------
-o
Administrator
i
i
i
i
i .
. i i
Regional
Administrator
(10)
I
L
Environmental
Services
Organizations
- New England
Regional
Laboratory,
Lexington, MA
-Edison, NJ
- Central Regional
Laboratory,
Annapolis, MD
-Athens, GA
-Chicago, IL
- Houston, TX
Kansas City, Kb
- Denver, CO
- Environmental
Monitoring Systems
Laboratory,
Richmond, CA
L- Seattle, WA
^sslstant Administrator
for Air and Radiation
Office of Radiation
and Indoor Air
[- NAREL
L- ORIA/LV
Office of Air Quality
Planning and
Standards
1— Emission
Measurement
Laboratory
Oftice of Mobile
~ Sources
L-NVFEL
Associate Administrator
for Regional Operations
and State/Local
Relations
Office of Envlronmenta
Processes and Effects
Research
- ERL/GB
- ERL/ATH
ERL/DUL
' — Large Lakes Research
Station (Gross* lie, Ml)
-ERL/ADA
-ERL/COR
-ERL/NARR
' — Pacific Ecosystems
Branch (Newport, OR)
Office of Health
Research
LHERL/RTP
Office of Exploratory
Research
Office of Research
Program Management
Science Advisor
I i
Assistant Administrator Assistant Administrator
for Research and for Prevention, Pesticides,
Development and Toxic Substances
Assistant Administrator
for Water
1
Office of Modeling, „. . _ ....
Monitoring Systems Offlce of Pesticlde
and Quality Assurance Programs
-AREAL
-EMSL/I
L-Env
Pht
Cer
L-EMSLA
|_ Office of Qroundwater
and Drinking Water
TRIP - Environmental L- TSD/CIN
_V Chemistry Laboratory
W^W"0" Laboratory
,.,. "— Microbiological
"IN Laboratory
Office of Environmental
Engineering and
Technology
Demonstration
^AEERL
L RREL/C
1 — Rel
(Ed
/RTP
;IN
Bases Control Branch
son, NJ)
Assistant Administrator
for Administration and
Resources Management
"—Data Processing
Laboratory
Assistant Administrator
for Enforcement
1
1 1 1
Office of Health and Office of
Environmental L Enforcement
Assessment
-ECAO/I
-ECAO/(
L- Human
Group
Office
— Planning,
Ev
TTP
:IN
re Assessment Group
Health Assessment
LNEIC
Assistant Administrator
for Solid Waste and
Emergency Response
of Science,
and Regulatory
aluatlon
-
-
Note: Laboratories are shown in bold type
Figure 7-1. Current Laboratory Structure
-------
Table 7-1. Distribution of FY93 Scientific and Technological Resources
Policy Level
ORD
Regional Administrator (10)
Air and Radiation
Enforcement
Prevention, Pesticides, and
Toxic Substances
Water
Laboratory
FTEs
1535
639
357
120
34
23
Funding
($000)
$392,516
49,406
46,700
13,917
2,996
2,096
Note: FTE totals are drawn from Figures 4-2 and 4-3; funding totals are drawn from
Table 4-8 and Appendix A, Table 2 for individual laboratories.
7.2.2 Customer Orientation
Organizations, whether they be production, service, or scientific corporations, are now
giving increased attention to customer needs. As a regulatory agency, EPA has to address
two broad types of customer needs: the need for technical input to the development,
implementation, and enforcement of environmental regulations addressed to identified or
suspected problems and the need to anticipate and characterize as yet unidentified human
health and ecological issues. Based upon interviews with customers for EPA's science and
technology, both internal and external to EPA, there is neither a clear understanding on
where to seek products or technical support within ORD nor an effective means to
transfer scientific and technological knowledge in a timely manner to those who need it.
The regional and program office laboratories are now more focused on customers than are
the ORD laboratories, so this option would not affect them as much.
The Customer Orientation option postulates a greater alignment with the customers of
the laboratories. It is intended to put ORD and program office laboratories more directly
under the control of the program offices they serve and supports the mission of the
conduct of research and the use of the information in strengthening environmental
protection programs. As shown in Figure 7-2, it establishes a new structure for the
program offices and ORD laboratories, with consolidation occurring within the dashed
boxes. The proposed organization retains the current structure and reporting relationships
of the ESOs (except where they are impacted by consolidation) and NEIC, since these
organizations now have a customer orientation. Under this option, the ESO laboratories,
not including the quality assurance/quality control and field monitoring functions, would
7-4
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Administrator
Associate Administrator
for Regional Operations
and State/Local
Relations
Quality Assurance
Management Staff
Science Advisor
Assistant Administrator
for Air and Radiation
-i New England
iReglonal
i Laboratory,
i Lexington, MA
JEdlson, NJ
— Central Regional
,Laboratory,
(Annapolis, MD
—•Athens, GA
-'Chicago, IL
— Houston, TX
—iKansas City, KS
-> Denver, CO
-^Richmond, CA
L, Seattle, WA
Office of Radiation
and Indoor Air
HNAREL' '
ORIA/LV'
Office of Air Quality
Planning and
Standards
-1 Emission ,
' Measurement,
| Laboratory
lAEERL/RTP
Office of Mobile
Sources
L
NVFEL
Consolidation proposed
Office of
Exploratory
Research
Assistant Administrator
for Research and
Development
J_
Assistant Administrator
for Prevention, Pesticides,
and Toxic Substances
Office of Ecological
Systems Research
Office of Pesticide
Programs
-1ERL/GB
^ERUATH
TERL/DUL
' — Large Lak» R**Mrch
1 Station (Orcnu ll«, Ml)
-|ERL/ADA
-(ERL/COR
-'ERL/NARR
'— Pacific Ecoiyttoms
Branch (Newport, OR)
-i Environmental
> Chemistry Laboratory
—| Analytical Chemistry
| Laboratory
•(Microbiological
' Laboratory
Office of Health
Research
HHERL/RTP
j— Exposure Assessment Group
Human Health Assessment
Group
Office of
Environmental
Characterization
and Monitoring
-AREAL/RTP
- EMSULV
-Data Processing
Laboratory
Assistant Administrator
for Water
Office of Groundwater
and Drinking Water
HTSD/CIN j
JEMSL/CINi
L-"ECAO7cflN
Assistant Administrator
for Administration and
Resources Management
Assistant Administrator
for Enforcement
Office of
Enforcement
L
NEIC
Assistant Administrator
for Solid Waste and
Emergency Response
L
RREL/CIN
'—Releoui Control Branch
(EcKton, NJ)
Figure 7-2. Structure for Customer Orientation Option
-------
be consolidated from the present ten to a number to be determined through an analysis of
such factors as sample analysis requirements, present state of laboratory facilities and
equipment, cost of maintaining current facilities, and whether facilities are leased or
owned.
Some of the functions that the ESOs perform, such as methods development,
enforcement, and certification, may be inherently governmental. All of these functions
require laboratory facilities. Because of this, there is a necessity to have some level of
analytical capability. The staff in the ESO tend to be more mature and to remain at the
ESOs longer than their counterparts in commercial laboratories. If laboratories are
consolidated arbitrarily, EPA might lose its most experienced staff and lose the
satisfaction of its customers that it now enjoys.
Figures 7-3 through 7-8 present the distribution of FTEs among science and
technology functions for the new groupings that this option would create (laboratory
groupings are indicated by the labeling of the Y-axis in each graph).
The Office of Radiation and Indoor Air (ORIA) would retain control of the two
radiation laboratories located in Las Vegas and Montgomery. These two laboratories
(Figure 7-3) are heavily weighted to the implementation of Agency monitoring and
assessment mandates relating to environmental radiation and are well constituted to serve
their program office. There is essentially no fundamental or other research that should be
considered for relocation.
Three laboratories would answer to OAQPS in support of its efforts to develop
regulations and technologies (Figure 7-4). This would concentrate most of the
development and application-directed research capabilities for air in the Agency and
would entail the "misplacement" in a line organization of very little current fundamental
research activity. That small amount could be transferred into another suitable
organization devoted to fundamental research.
Figure 7-5 shows the distribution of FTEs for the laboratories that would support an
Office of Ecological Systems Research: the Environmental Research laboratories and field
stations. This grouping plainly is focused on fundamental and applied research almost
exclusively. This fits well into the placement of the office under ORD.
An Office of Health Research within ORD would inherit control of the HERL,
HHAG, and EAG. Figure 7-6 shows that this would group substantial FTE resources in
the functions of application-directed and fundamental research, development, quality
oversight, technical assistance, and technology transfer.
7-6
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[COO-FUNC.XLWJFIG7-3.XLC
S&T Function
FTE
Laboratory
Figure 7-3. FTE by Scientific and Technological Function
Office of Radiation and Indoor Air
(Customer Orientation Option)
-------
[COO-FUNC.XLW]FIG7-4.XLC
50
00
S&T Function
Laboratory
Figure 7-4. FTE by Scientific and Technological Function
Office of Air Quality Planning and Standards
(Customer Orientation Option)
-------
[COO-FUNC.XLW]FIG7-5.XLC
S&T Function 3
30 FTE
Laboratory
Figure 7-5. FTE by Scientific and Technological Function
Office of Ecological Systems Research
(Customer Orientation Option)
-------
[COO-FUNC.XLW]FIG7-6.XLC
S&T Function
FTE
Laboratory
Figure 7-6. FTE by Scientific and Technological Function
Office of Health Research
(Customer Orientation Option)
-------
[COO-FUNC.XLWJFIG7-7.XLC
S&T Function
30 FTE
Laboratory
Figure 7-7. FTE by Scientific and Technological Function
Office of Environmental Characterization and Monitoring
(Customer Orientation Option)
-------
[COO-FUNC.XLW]FIG7-8.XLC
to
S&T Function
FTE
Laboratory
Figure 7-8. FTE by Scientific and Technological Function
Office of Pesticide Programs
(Customer Orientation Option)
-------
Further, the HERL does not fit this picture very neatly, as it devotes more than a third of
its effort to fundamental research, and much of the application-directed research may be
closely tied to that fundamental research. Therefore, this option would place a mix of
functions in an ORD organization; these now have problems of mixed directions, as
discussed earlier. It would be useful to consider whether the functions of technology
transfer, technical, and quality oversight of the three laboratories could and should be
broken away and placed within appropriate program offices, leaving the research functions
within ORD.
The laboratories organized under ORD's Office of Environmental Characterization and
Monitoring (Figure 7-7) are heavily vested in implementation support activities, as well as
development, and some research. Viewed strictly from the perspective of this mission
analysis, these laboratories do not appear to fit as well under the ORD umbrella, and
might perpetuate problems with customer responsiveness in some activities and,
conversely, freedom to pursue fundamental research without the press of daily program
office, demands. These laboratories therefore would be candidates for splits of functions,
with research functions perhaps remaining with ORD, but implementation support
activities shifting, by medium, to the appropriate program offices.
The Environmental Chemistry Laboratories at Beltsville and Bay St. Louis would
continue to serve the Office of Pesticide Programs with their high degree of focus on
analytical support, technical assistance, and quality oversight (Figure 7-8). The two
laboratories virtually duplicate their emphasis on scientific and technological functions,
which raises the question of whether both are needed or whether some degree of
consolidation might be appropriate. In comments on the draft of this report, the Deputy
AA of the Office of Prevention, Pesticides, and Toxic Substances, stated that the
Beltsville laboratory would be collocated with the new Region 3 laboratory proposed for
construction at Ft. Meade, Maryland in FY96/FY97. He also supported the consolidation
of the Bay St. Louis facility at Ft. Meade.
No change would occur in support by the NVFEL to the Office of Mobile Sources.
The distribution of scientific and technological functions at that laboratory is a close fit to
the daily needs of the sponsoring program office, as there is no interfering structure to
inhibit direct responsiveness to the customer. In comments on the draft of this report, the
Director of the Program Management Office, Office of Mobile Sources, stated that the
NVFEL is the name of a facility to carry out Titles I and n of the Clean Air Act, fuel
economy and other energy-related legislation, and other programs, a laboratory in name
only. (Based on MITRE's observations during the visit to NVFEL, approximately 100 of
the reported 277 staff there are performing laboratory activities for vehicle testing and
certification.) In spite of this, the NVFEL is considered a laboratory for the purposes of
this study. Mobile sources research activities now at the ORD AREAL in Research
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Triangle Park, North Carolina (RTF) might be considered for consolidation into this group
or for treatment by another mechanism to ensure close communications and support to the
program office.
Without physical consolidation, this option would emphasize, through enhanced lines
of communication with customers, closer customer contact and direction. With physical
consolidation, the structural realignment would combine like functions to emphasize
customer responsiveness and enhance the quality of science.
7.2.3 Streamlining
As part of the National Performance Review, EPA is addressing how it can best
streamline its scientific and technological operations. This streamlining is directed toward
improving the efficiency and effectiveness of carrying out all the Agency missions. The
option, as addressed here, related only to ORD, although ESOs might be affected. ORD
has recommended (Sussman, 1994) separating strategic research from program support
research (at a minimum in planning and budgeting) to enhance decision making and
increase the responsiveness of the research program. Two suboptions, one without and one
with consolidation, are addressed under streamlining. Without consolidation, the
Streamlining option assumes administrative changes to the ORD organization. EPA has
stated (Sussman, 1994) that, based on a recent decision by the Office of Management and
Budget and the National Performance Review, because of EPA's projected increase in
FTE in FY95, it is unlikely that EPA will have to reduce Grade 14 and above non-
supervisory scientific positions. The assumption is made that any reductions in FTE would
take place primarily at EPA Headquarters. The proposed organization retains the current
structure and reporting relationships; the major change is likely to be in the reduction of
Headquarters staff. The evaluation of streamlining in ORD without consolidation in the
memo from the ORD laboratory directors (Marchant, 1994) concentrates on organizational
changes, with the reorganization of headquarters ORD, including the creation of the
Director of Research and Director of Program Planning and the elimination of much of
the headquarters ORD staff. Many of the current headquarters functions would then move
to the laboratory level.
The streamlining changes within ORD incorporate the recommendations presented in
the draft ORD report on Streamlining ORD (Foley, 6 February 1994) and the consensus
recommendations by the ORD Laboratory Directors Group (Marchant, March 1994). The
proposed ORD organization is shown in Figure 7-9. While the ORD laboratory directors
endorse the concept of some kind of aggregation of laboratories, they recommended that
the ORD laboratories be aggregated based on the following criteria:
7-14
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Assistant Administrator
Research and Development
Exploratory Research
Director of Program Planning
AA Support Staff
Functions:
• Quality Assurance
• Administrative Support
• Risk Assessment Forum
Director of Research
H
E
A
D
Q
U
A
R
T
E
R
S
Risk Assessment
LABORATORIES
(see discussion in text)
F
I
E
L
D
Figure 7-9. Laboratory Directors' Alternative
-------
• "Flagship, mega-laboratories" as the Carnegie Commission recommended should
not be created since all laboratories are carrying out important regulatory and
statutory duties of EPA.
Leadership—both scientific and managerial—should be concentrated in the field.
• Laboratory missions should be clarified to ensure that ORD research is
responsive to existing and emerging EPA needs, and redundant missions should
be avoided.
• Aggregation should result in and/or sustain "critical masses" in the disciplines
essential to success in ORD's research program. Any such aggregation should be
along disciplinary lines, with a multimedia emphasis.
Wherever possible, as with geographically collocated laboratories, services
should be consolidated.
• No extra layers of "bureaucracy" should result.
There should be no wholesale personnel relocations.
To date, the ORD laboratory directors have not recommended organizational units within
the Risk Assessment and Laboratories boxes on Figure 7-9, although several individuals
commenting on the draft of this report have presented the merits of retaining a structure
similar to the current one for risk assessment.
Consolidation is limited to convenient consolidation; that is, those laboratories that are
convenient to one another, or physically collocated, would be consolidated, while the
reporting relationships of the scientific and technological functions would be preserved.
For example, the Region 4 laboratory and the ORD laboratory located in Athens, Georgia
would be combined administratively to save on administrative expenses. They also would
share laboratories. Administrative and support specialist positions could be consolidated.
Although it might stretch the definition of "convenient consolidation", funds have been
approved by Congress for the construction of an EPA facility at Bay City, Michigan. This
is a possible location for a new laboratory for Region 5, as well as a new site for the
ORD Large Lakes Research Station (LLRS) now located at Grosse He, Michigan. The
Bay City location would allow for the expansion and consolidation of two Region 5
laboratories. Construction of a replacement for the World War Li-era converted warehouse
at LLRS would also be possible.
7-16
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7.2.4 Carnegie Commission
The Carnegie Commission (Carnegie Commission, 1992) recommended that the
existing structure of the ORD laboratories be consolidated to create a National Ecological
Systems Laboratory (NESL), a National Environmental Monitoring Systems Laboratory
(NEML), a National Environmental Engineering Laboratory (NEEL), and a National
Health Effects Laboratory (NHEL). This approach, which acknowledges the need for
integrated long-range research and addresses the multimedia nature of environmental
problems, forms the basis of the Carnegie Commission option. No changes would be
made in the current structure or reporting relationships of the program office laboratories
and ESOs. A nationally prominent scientist-administrator would serve as the director of
each of the national laboratories and would report to the AA for Research and
Development. As with all the other options, the management improvements proposed in
Section 6 would be applied as appropriate under this option.
The proposed ORD organizational structure is shown in Figure 7-10. The NESL would
be formed by combining the six existing EPA R&D laboratories. A new headquarters site
would be established for the national laboratory, with some of the existing laboratories
continuing to operate as field sites under the direction of the national laboratory. The
existing laboratories are located at Corvallis, Oregon; Duluth, Minnesota; Gulf Breeze,
Florida; Narragansett, Rhode Island; Ada, Oklahoma; and Athens, Georgia. Three
laboratories in ORD devoted to environmental monitoring (the EMSLs in Cincinnati,
Ohio, and Las Vegas, Nevada, and the AREAL in RTF) would be combined to form the
NEMSL. A headquarters site would be established for the NEMSL, with the existing
laboratories continuing to operate as field sites under its direction. The NEEL would be
established by combining the existing EPA RREL in Cincinnati, Ohio, and the AEERL in
RTP. The main laboratory, in North Carolina, would focus on air and energy engineering,
and the Cincinnati component of the laboratory would focus on water quality-related
laboratory research and risk reduction. The existing HERL in RTP would be raised to the
same status as the other three proposed EPA national laboratories.
The effect of this consolidation on the distribution of scientific and technological
functions is illustrated in Figures 7-11 through 7-14. Since the Carnegie Commission
option focuses on grouping laboratories by gross discipline category, the distribution of
scientific and technological functions would remain unchanged, and the only major shifts
would occur because the laboratories within a particular group share certain functional
characteristics. For example, the laboratories identified with the NESL are heavily vested
in fundamental and application-directed research, while the laboratories comprising the
NEML perform a wide range of other scientific and technological functions but little
fundamental research.
7-17
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Administrator
Associate Administrator
for Regional Operations
and State/Local
Relations
Quality Assurance
Management Staff
Science Advisor
i—»
oo
New England
Regional
Laboratory,
Lexington, MA
- Edison, NJ
- Central Regional
Laboratory,
Annapolis, MD
Athens, GA
- Chicago, IL
— Houston, TX
- Kansas City, KS
— Denver, CO
— Richmond, CA
- Seattle, WA
Assistant Administrator
for Air and Radiation
-
Office of Radiation
and Indoor Air
UNAREL
L- ORIA/LV
Office of Air Quality
Planning and
Standards
*— Emission
Measurement
Laboratory
Office of Mobile
Sources
L
NVFEL
Assistant Administrator
for Research and
Development
National Ecological
Systems Laboratory
- ERL/QB
- ERL/ATH
ERL/DUL
'—Large Lakei Research
Station (Qroiu II*, Ml)
-ERUADA
-ERL/COR
-ERL/NARR
I
Pacific Ecotyttemi
Branch (Newport, OR)
National Health Effects
Research Laboratory
_L
Assistant Administrator
for Prevention, Pesticides,
and Toxic Substances
National Monitoring
Systems Laboratory
Assistant Administrator
for Water
Office of Pesticide
Programs
-AREAL/RTP
EMSL/LV
'— Environmental
Photographic Interpretation
Center (Warrantor!, VA)
•EMSL/CIN
Office of Groundwater
and Drinking Water
-Environmental
Chemistry Laboratory
• Analytical Chemistry
Laboratory
• Microbiological
Laboratory
L
TSD/CIN
National
Environmental
Engineering
Laboratory
Assistant Administrator
for Administration and
Resources Management
L
Data Processing
Laboratory
k-AEERL/RTP
LRREL/CIN
'— ReleaMt Control Branch
(Edton, NJ)
Assistant Administrator
for Enforcement
Office of Health and
Environmental
Assessment
Office of
Enforcement
-ECAO/RTP
-ECAO/CIN
-Exposure Assessment Qroup
—Human Health Assessment
Qroup
L
NEIC
Assistant Administrator
for Solid Waste and
Emergency Response
Figure 7-10. Structure for Carnegie Commission Option
-------
[CCO-FUNC.XLW]F1G7-11 .XLC
S&T Function s
-30 FTE
Laboratory
Figure 7-11. FTE by Scientific and Technological Function
National Ecological Systems Laboratory
(Carnegie Commission Option)
-------
[CCO-FUNC.XLW]FIG7-12.XLC
70
60
FTE
to
o
S&T Function
S.
Figure 7-12. FTE by Scientific and Technological Function
National Monitoring Systems Laboratory
(Carnegie Commission Option)
-------
[CCO-FUNC.XLW]F1G7-13.XLC
to
S&T Function
FTE
Laboratory
Figure 7-13. FTE by Scientific and Technological Function
National Environmental Engineering Laboratory
(Carnegie Commission Option)
-------
ICCO-FUNC.XLW]FIG7-14.XLC
^J
I
to
S&T Function
o
33
1 O
> fi Laboratory
Figure 7-14. FTE by Scientific and Technological Function
Office of Health and Environmental Assessment
(Carnegie Commission Option)
-------
Figures 7-15 through 7-18 show the effect of the Carnegie Commission consolidations
on the distribution of professional degrees within the laboratories. This would produce the
following groupings: the NESL would be staffed mostly by biologists, the NEMSL would
be staffed by chemists and biologists, the NEEL would be staffed mainly by engineers,
and the NHEL would be staffed by biologists (disciplines grouped as bio-sciences). These
groupings appear workable, although it is possible that more physicists and engineers
would be desirable within the NEMSL.
In its study, the Carnegie Commission did not consider several units that are a part of
the current ORD organization but that have been included in the baseline. For purposes of
this option, an office reporting to the AA for R&D, the Office of Health and
Environmental Assessment, which includes the ECAOs in RTF and Cincinnati, and the
EAG and the HHAG in Washington, have been retained. The functions of the Office of
Exploratory Research would be incorporated into the responsibilities of each of the four
national laboratories. The EPIC would be would be incorporated into the NEMSL, the
Pacific Ecosystems Branch and the LLRS into the NESL, and the RCB into the NEEL.
Although not considered as a part of the structural changes addressed in this option,
the Carnegie Commission further recommended the EPA should establish and support up
to six major Environmental Research Institutes (ERI) in association with academic
institutions and nongovernmental organizations across the country. The need for such
extramural research capability was addressed as part of the management improvements.
The evaluation of the Carnegie Commission option is divided into two portions. The
first considers implementation of the recommendations without physical consolidation of
the laboratories. It was also assumed that in this case the directors of each of the national
laboratories would reside at EPA headquarters and that each laboratory would have an
administrator reporting to its director. The assumption was also made that the national
laboratory directors would absorb research planning tasks currently performed by
headquarters offices and that most administrative tasks would be pushed down to the
laboratory administrator level. The second portion of the analysis includes these same
assumptions combined with actual physical consolidation of the laboratories into single
locations for each of the national laboratories. In this case, the directors of the national
laboratories would reside at the laboratories. The bulk of the planning and administrative
tasks would occur at the laboratories with only a small supporting staff at headquarters.
7.2.5 Distinct Environmental Services Organization
The DESO option considers only those organizations that primarily perform technical
assistance and services within EPA, i.e., the ESOs and the program office laboratories.
This option, shown in Figure 7-19, would place the program office laboratories and ESOs
7-23
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FIG7-15.XLC
Chemistry
Physics
Earth Sciences
Phys. Scl., Other
Agric./Soil Sci.
Env. Science/ Conservation
Bio-Sciences
Health Pros
Math/Stat.
Engineering
Computer/ Info. Sci.
Interdisciplinary
Business Mgmnt/Admin.
100
80
Discipline
Other
60
FTE
40
20
ORD/ERL7NARR
ORD/ERL/GB
ORD/ERUDUL
ORD/ERL/COR
ORD/ERUATH
ORD/ERL7ADA
Lab
Figure 7-15. FTE by Discipline (Degrees)
National Ecological Systems Laboratory
(Carnegie Commission Option)
-------
FIG7-16.XLC
to
Discipline
0
ORD/EMSL/LV
ORD/EMSL/CI
ORD/AREAL/RTP
Lab
Figure 7-16. FTE by Discipline (Degrees)
National Monitoring Systems Laboratory
(Carnegie Commission Option)
-------
FIG7-17.XLC
to
Discipline
ORD/AEERL7RTP
Lab
Figure 7-17. FTE by Discipline (Degrees)
National Environmental Engineering Laboratory
(Carnegie Commission Option)
-------
FIG7-18.XLC
Discipline
ORD/ECAO/RTP
ORD/ECAO/CIN
ORD/EAG/DC
ORD/HHAG/DC
Lab
Figure 7-18. FTE by Discipline (Degrees)
Office of Health and Environmental Assessment
(Carnegie Commission Option)
-------
Administrator
Science Advisor
Assistant Administrator
for Air and Radiation
to
00
Office of Radiation
and Indoor Air
Office of Air Quality
Planning and
Standards
Office of Mobile
Sources
Assistant Administrator
for Research and
Development
Office of
Environmental
Processes and
Effects Research
Office of Health
Research
Office of Exploratory _j
Research
Office of Research
Office of Modeling,
Monitoring Systems
and Quality Assurance
Office of Environmental
Engineering and
Technology
Demonstration
Office of Health and
Environmental
Assessment
Office of Science,
Plannino. and
Management
Regulatory Evaluation
Assistant Administrator
for Environmental
Services
_L
Assistant Administrator
for Prevention, Pesticides,
and Toxic Substances
-NEIC
- ESDa/ESBs
-NAREL
- ORIA/LV
- Emission Monitoring
Lab (OAQPS)
- NVFEL
- Data Processing
Laboratory
- TSD/CIN
— OPP Laboratories
Assistant Administrator
for Water
Office of Pesticide
Programs
Office of Groundwater
and Drinking Water
Assistant Administrator
for Administration and
Resources Management
Assistant Administrator
for Enforcement
Office of
Enforcement
Assistant Administrator
for Solid Waste and
Emergency Response
Figure 7-19. Structure for Distinct Environmental Services Organization Option
-------
under a new AA who would make all national-level decisions and allocations of work and
resources according to a consolidated view of the whole of such direct support
requirements. Where applicable, the management improvements identified earlier would
be implemented under this option, as well as laboratory consolidations noted in the
streamlining option.
The DESO option recognizes the importance of technical assistance and services to the
fulfillment of EPA's mission of establishing and enforcing environmental protection
standards, as well as the mission of providing assistance to others to arrest pollution of
the environment. Consolidation of similar functional activities within the ESOs is also
proposed as part of this option, and the organizational units incorporated into the ESOs
are as follows:
• National Enforcement Investigations Center
• Environmental Services Organizations
• National Air and Radiation Environmental Laboratory
• Office of Radiation and Indoor Air Laboratory
• OAQPS Emission Measurement Branch
• National Vehicle and Fuel Emissions Laboratory
• National Data Processing Division Data Processing Laboratory
• Office of Ground Water and Drinking Water Technical Support Division
Office of Pesticide Programs
Environmental Chemistry Laboratory
Analytical Chemistry Laboratory
Microbiological Laboratory
• Regional Environmental Services Laboratories
This option creates a rich resource pool for executing the implementation activities of
the Agency's mission, and provides many opportunities for constructive consolidation of
services within geographic regions and particular service functions. An AA could begin
operations with the current suite of laboratories and personnel, and, through experience
with performance and cost-effectiveness in a series of assignments to each laboratory,
assess where such consolidation would be most beneficial.
Changes to ORD, which are discussed above, are not included in this discussion. This
permits the analysis of the impacts of changes on research functions (Carnegie
Commission option) and technical assistance and services functions (DESO) separately.
This structure also allows for the analysis of consolidation of both types of laboratories by
combining the two options.
7-29
-------
Figure 7-20 illustrates the groupings of scientific and technological functions (as
measured by FTEs) that result from this organizational consolidation. Taken together,
these organizations are focused almost perfectly on the implementation activities of
Agency mission execution, with consistent representation in key activities, such as
enforcement/compliance, monitoring, technical assistance, and analytical support.
Figure 7-21 shows the effect of the same groupings on available professional degrees.
This picture resembles the overall average for all EPA laboratories combined—heavy
concentrations in the biological sciences, chemistry, and engineering disciplines. In a more
ambitious Environmental Services framework, it would be necessary to consider
increasing the representation of other disciplines, such as the earth sciences for support of
hazardous waste, more health professionals, and more computer scientists.
It might be argued that this consolidation deprives both the program offices and the
Regional Administrators of the direct customer-supplier relationships they now enjoy, and
that this option therefore moves in the exact opposite direction of more customer
orientation. Counter to this is the possibility that the AA for Environmental Services
would define his/her role as a broker and supplier of services to the customer
organizations, and would refrain from interposing barriers to very direct service to those
customers. The most effective means of ensuring this would be to make the budgets of
the ESOs largely or completely dependent on "sales" of services to the customer
organizations. Market forces could be expected to drive the ESOs rapidly toward the most
cost-effective combinations of providers to meet the implementation scientific and
technological needs of the Agency.
For purposes of evaluating this option, it was assumed that the AA for the ESOs
would make all national level decisions including responsibility to oversee the evolution
of types of services to be provided by particular laboratories and the laboratories moving
into the ESO, and that the program offices would "buy" services from the associated
allocations of resources for facilities and equipment. It was also assumed that core
resources for basic regional environmental laboratory services would come from the ESO
and that additional services would be paid for by regional programs requesting services
not covered by the core resources. It was assumed that the two other core regional
environmental services, QA/QC and field monitoring, would remain within the regional
offices but that QA/QC would be moved out of existing ESOs and would report to either
the Office of the Regional Administrator or to some other non-program regional office. A
disadvantage of this configuration is that it would separate the QA/QC staff from the day-
to-day contact in the laboratory that keeps their skills current.
This option has been considered both with and without physical consolidation. Without
physical consolidation, the changes would be purely administrative, with all laboratories
7-30
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FIG7-20.XLC
Application-Directed Research
Fundamental Research
Development
Enforcement/Compliance
Monitoring
Quality Oversight
Technical Assistance
Technology Transfer
Analytical Support
State/Local Oversight
S&T Function Emergency Response
120
100
60 FTE
Laboratory
Figure 7-20. FTE by Scientific and Technological Function
Distinct Environmental Services Organization (DESO) Option
-------
[DESO-OPT.XLW]FIG7-21 .XLC
-J
i
LO
to
Chemistry
Physics
Earth Sciences
Phys. Sci., Other
Agric./Soil Sci.
Env. Science/ Conservation
Bio-Sciences
Health Pros
Math/Slat.
Engineering
Discipline Computer/ Info. Sci.
Interdisciplinary
Business Mgmnt/Admin
Other
-60
8N
\ OAR/OAQPS/E
S
?
30
-1
T>
*>
OAR/NAREL/MO
Z
H
r^
OAR/NVFEL/AA
O
E7NEIC/DEN
8
WDWATSD/CIN
Lab
Figure 7-21. FTE by Discipline (Degrees)
Distinct Environmental Services Organization (DESO) Option
-------
remaining located as they presently are. Under the consolidation scenario, there would be
physical consolidation of the ESOs, with fewer than ten remaining.
7.2.6 Geographic Location
It is apparent that protection of the environment is a complex problem that demands
an integrated approach that encompasses all media and focuses on human health and
ecological factors. To a great extent, EPA's laboratories, especially the ORD and program
office laboratories, currently are organized to address medium-specific issues and either
human health or ecosystem impacts. The Geographic Location option is proposed to
address integration across medium, human health, and ecological factors. Geographic
locations are used as an organizing element to provide context for both research and
customer needs. The option takes advantage of matrix management for integration of
capabilities throughout the Agency. Initially, the current locations and reporting
relationships of all of EPA's laboratories would be retained. Over time, there could be a
realignment and replication of facilities, equipment, and staff within each of the defined
geographic areas.
To analyze the merits of this option, it is not necessary to define the specific
geographic regions, or provinces. In general, the major ecosystems found in the
continental United States, such as the Ecoregions of the Continents defined by the Forest
Service of the U.S. Department of Agriculture, or the river basin regions defined by the
U.S. Army Corps of Engineers could serve as the basis for organizing the system program
offices under this option. A third possibility is to expand the number of regions now
included in ORD's ecological research initiative to encompass the entire country including
Alaska and Hawaii. A fourth possibility is to embody the place-based reorientation
concept proposed through the Edgewater Consensus (Perciasepe, Gardiner, and Cannon,
16 March 1994).
The organizational structure for the Geographic Location option assumes that each
province would have an ecosystem program manager. The reporting chain for this option
could take one of at least two alternative forms, depending on whether the emphasis is on
place-based research or place-based action (implementation of environmental protection
measures). If the emphasis is on research, then a logical arrangement would be to have
the ecosystem program managers report to a central office directly under ORD
management. On the other hand, with environmental protection action as the driver, then
each ecosystem program manager would most appropriately report directly to the
cognizant Regional Administrator. In this latter case, the Associate Administrator for
Regional Operations would take responsibility for a coordination role to facilitate the
cross-region communication and reporting needed to maximize the national benefit from a
place-based environmental protection program.
7-33
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For technical coordination and integration among the place-based ecosystem programs,
a central, dedicated ecosystems protection team is proposed. This team would perform a
variety of functions, as required by the ecosystem program managers and/or Headquarters,
to support the ecosystem concept for environmental protection. Included in these functions
could be the construction, maintenance, and dissemination of a lessons-learned database to
maximize the Agency-wide experience base in place-based environmental protection and
ecosystems management.
The Geographic Location option was evaluated both with and without physical
consolidation which entails relocation. For the option without physical consolidation, the
ecosystem program manager would be responsible for providing the necessary research to
support the programs located within the province. This would include technical support to
the media-based program offices and to the state and Native American governments. It
was also assumed that the ecosystem program manager would control the resources to
support these activities and that the laboratories would be providers of research services
and would seek support from the ecosystem program managers.
In addition to the organizational changes proposed above, the physical consolidation
suboption assumes that each province would have a laboratory, either through conversion
of existing laboratories or establishment of a new laboratories for provinces that do not
now have any laboratory facilities. This option would affect all three types of laboratories,
since the existing laboratories of all types would be converted into centers for the specific
geographic area. In contrast to the other options, where physical consolidation would lead
to a smaller number of larger facilities, the physical relocation aspect of this option would
lead to a larger number of smaller facilities. Thus, there would be more redundancy rather
than less. This option also assumes that there would be duplication of basic laboratory
services among the provinces and that there would be duplication of more specialized
services required by provincial conditions (i.e., more than one province could have a need
for marine sciences). Research into areas of interest for the province would be
concentrated in the laboratory for that province.
7.3 EVALUATION CRITERIA
For this study, MITRE has performed an objective, but not quantitative, evaluation of
the quality of the scientific and technological products and the effectiveness and efficiency
of laboratory operations (human resources, equipment, and facilities) and determined the
responsiveness of scientific and technological functions to EPA's needs. In order to
evaluate the options discussed previously, criteria were developed from several sources.
Criteria were proposed in the Final Study Plan (11 February 1994) prior to visits to the
laboratories. Criteria also were suggested by several groups, among them the ESD Work
7-34
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Group (Rhoades, 2 February 1994). Following the series of visits to the laboratories, it
became apparent that the criteria suggested previously were too numerous and too specific
to be useful in analyzing the options. The criteria defined in this section were developed
to provide differentiation among the options and evaluation of the impacts of the options.
As the study progressed, it became apparent that the quality of the products of the
laboratory operations are generally high and that this was not the major issue; the
application of these scientific and technological products throughout the regulatory process
is. Thus, in the quality criteria that are used to evaluate the options, the emphasis has
shifted from the quality of the science to preserving the quality of the science in its use.
The evaluation criteria are divided into three categories: effective use of agency
resources, efficient use of agency resources, and implementation. The evaluation using
these criteria indicates the quality of any changes from the current conditions. This
includes evaluation of the continuation of the existing baseline and whether conditions
would improve, remain the same, or deteriorate if conditions remain unchanged. The
administrative impediments issues discussed in Section 6 were not included in these
criteria as the evaluation assumed that the management improvements discussed in
Section 6 would be applied to all of the options. No attempt has been made to weigh the
criteria for this analysis.
7.3.1 Criteria for Effective Use of Agency Resources
In the examination of the effective use of agency resources criteria, each option was
examined for its impact in each of the following seven areas:
• Science Quality/Utility: Does the option facilitate the production and use of
science of the highest quality throughout the Agency to support all facets of its
environmental protection mission? Each option was evaluated for its potential to
provide opportunities to increase the quality of science through enhanced
interactions among scientific and technological personnel of similar disciplines.
Interactions across disciplines among researchers focused on problems within the
same or associated media, environments, or other cross-program or cross-
disciplinary areas were also considered.
Stature/Credibility: Does the option provide potential for enhancement and
maintenance of the professional stature and credibility of the scientific and
technological staff? Evaluation of the options under this criterion included the
ability of the scientific and technological staff to produce research within their
respective fields of sufficient merit to enhance and maintain their professional
stature and credibility. Options were also evaluated for organizational changes
7-35
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that would enhance the stature and credibility of the scientific and technological
staff through creation of physical or administrative units that themselves have
enhanced credibility and stature as organizations.
Concentration of Resources: Does the option permit sufficient concentration of
specialized scientific and technological support resources (e.g., facilities,
equipment, critical skills, critical mass) to conduct high quality research and
support services activities within EPA? Options were evaluated on their potential
to increase interaction and information transfer among intramural staff. Each
option's potential for increasing access to shared equipment and facilities, ability
to support specialists, and creation of an accessible pool of technical and
administrative support personnel was also considered.
Geographic Location: Does the option provide for access to resources necessary
to carry out the assigned mission? Evaluation using this criterion included access
to unique geographical and environmental factors necessary to conducting high-
quality research and efficient delivery of technical support as well as well as
access to customers and support resources such as academic institutions, related
industries, and pools of scientific and engineering talent.
Mission Focus: Does the option improve the mission focus? As identified in
Section 5.2.1, the various portions of the laboratory and environmental services
system can provide a wide range of services while being subject to conflicting
demands and expectations. Under this criterion, options were evaluated for their
potential to provide increased focus on specific areas of expertise by the subject
portions of the laboratory and environmental services system.
Customer Satisfaction: Does the option improve system ability to satisfy
customer needs? The expectations and demands of the implementing program
offices and their related customers impact directly on use of and satisfaction with
products and services. The options were evaluated for their potential to increase
the system's ability to determine customer needs and expectations and the
subsequent ability to meet these needs and expectations. Issues related to
communication with customers were included within this criterion.
Use of Intramural Workforce: Does the option maximize the effectiveness of
the use of EPA's intramural workforce? With this criterion, the options were
evaluated for their ability to promote the effective use of the intramural
workforce. This included items such as an option's ability to support
administrative and support specialists to free researchers to do research instead of
7-36
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other activities (contract management or other administrative tasks) and increased
use of scientific and technological skills of available intramural personnel.
7.3.2 Criteria for Efficient Use of Agency Resources
In the examination of the criteria for the efficient use of agency resources, each option
was examined for its impact in each of eight areas:
• Multimedia Approach: Does the option enhance the Agency's ability to address
multimedia interdisciplinary issues? The options were evaluated for their
potential to enhance the Agency's multimedia capabilities. Linkages between
medium-based programs and specialists, opportunity for multidisciplinary and
multimedia team formation, and elimination of administrative and organizational
barriers were all considered.
• Priorities: Does the option ensure that resources and organizations are focused
on the highest-priority environmental problems and Agency support needs?
Under this criterion, the options were evaluated for their ability to enhance the
Agency's setting of goals and objectives for research, as well as the
implementation and the administration of the implementation of these goals and
objectives. Consideration was also given to the question of whether an option
enhances the Agency's ability to discern the priorities of its customers or
enhances its ability to perceive current or emerging environmental problems
requiring research.
• Functional Alignment: Does the option ensure that resources and organizations
are focused on Agency support needs by clarifying organizational responsibilities
and reducing functional redundancy? Options were evaluated for their potential
to use consolidation to reduce redundancy and increase structural alignment with
customers.
• Operating Costs: Does the option provide potential cost savings? Options were
evaluated for their potential to provide cost savings, including costs for travel,
required space, bringing existing facilities and equipment up to standard,
administrative services and equipment, and long-term operations and maintenance
costs, including supplies.
Facilities and Equipment: Does the option provide for more efficient use of the
resources available for facilities and equipment? Under this criterion, the options
were evaluated for their potential to use the existing infrastructure (including
operations and maintenance costs) more efficiently, as well as maximizing the
7-37
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return from new investments in facilities and equipment. This evaluation
included utilization rates, duplication of facilities and equipment across the
laboratory system, and the existing condition of facilities and equipment.
• Future Investments: Does the option lead to optimal future investments in
facilities or equipment? Required investments both to preserve and maintain
existing equipment and facilities and to acquire facilities and equipment needed
to maintain an appropriate level of technology were considered.
• Locus of Control: Does the option resolve locus of control issues raised during
the study? Locus of control issues, as described in Section 5.2.3, relate to the
distribution of administrative and decision-making authority. The options were
evaluated on their potential to resolve these issues through changes in the
decision-making hierarchy, the redistribution of control of resources, and the
method of selection of projects, tasks, and research topics.
• Use of Human Resources: Does the option optimize the number of human
resources required to achieve assigned tasks? The options were evaluated for
changes in the level of human resources that would result from option
implementation. This included decreases in human resources resulting from
flattening the organizational structure, streamlining, and consolidation. However,
increases in total human resources from contractor conversion were not
considered a negative impact for an option.
7.3.3 Criteria for Implementation
The following are the general criteria developed to evaluate the results of the
implementation of the option.
• Implementation Time: Can the option be implemented in reasonable time with
minimal disruption of key research and support functions? Factors for this
criterion included the required magnitude of construction of new facilities and
numbers of individuals requiring relocation. Numbers of organizational units and
individuals impacted by changes in organization and administration were also
considered. It was assumed that the amount of disruption increased at least
proportionally to the amount of relocation required.
Implementation Costs: What is the magnitude of costs required to implement
and maintain the option? Gross estimates were used to assign relative magnitudes
of implementation costs. Costs associated with administrative or organizational
changes without any associated physical relocation were assumed to be minimal.
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SECTION 8
EVALUATION OF OPTIONS
8.1 INTRODUCTION
The purpose of this section is to analyze the options that have been presented in terms
of their effect on improving the efficiency and effectiveness of the EPA laboratory
operations and of the cost and time required for implementation. Decisions on the option
or options to be pursued and the means through which they may be implemented rest with
EPA's management. No options are recommended, although some have been evaluated as
having more positive aspects, in terms of the evaluation criteria, than others.
In analyzing the options, the missions of the Agency, as discussed in Section 4, have
been considered, as well as EPA's leadership role for the federal government in
environmental protection. EPA's responsibilities for environmental protection require a
balance between the need for technical assistance, including scientific information
gathering and analysis, to support current issues relating to regulation, and the need for
fundamental and applied research to strengthen the understanding of human and ecological
environmental systems. Achieving this balance requires attention to priorities and to the
deployment and use of all resources most effectively. It also requires attention to the
needs of EPA's internal and external customers. The options are evaluated on the basis on
their effects on the needs for both types of services.
8.2 METHODOLOGY FOR ANALYSIS
Each option was evaluated against the criteria given in Section 7 by a panel of
MITRE staff who were familiar with the laboratories from personal experience in visiting
the laboratories, interviewing EPA personnel, and analyzing data from the laboratories.
Table 8-1 shows the effects of implementing each option. All the laboratories are
considered as a whole for the analysis, except for those options, such as Carnegie
Commission or DESO, that involve only a specific group of laboratories. Throughout the
analysis, the management improvements discussed in Section 6 are assumed to have been
implemented.
The symbols on Table 8-1 indicate the strength of the potential effects from the
implementation of options. Their meanings are as follows:
8-1
-------
Table 8-1. Evaluation of Options
Option
Customer Orientation w/o consolidation
Customer Orientation w/ consolidation
Streamline w/o consolidation
Streamline w/ consolidation
Carnegie w/o consolidation
Carnegie w/ consolidation
Distinct ESO (DESO) w/o consolidation
Distinct ESO (DESO) w/ consolidation
Geographic w/o consolidation
Geographic w/ consolidation
EFFECTIVE USE OF AGENCY RESOURCES
Science Quality/Utility
O
O
O
o
o
+
o
+
+
+
Stature/Credibility
O
O
O
o
+
+
+
+
o
o
i
a
TO
M
O
+
O
+
o
•n-
o
+
o
+
Geographic Location
O
O
O
o
o
o
o
-
0
++
Mission Focus
+
+
O
O
+
++
+
+
+
+
Customer Satisfaction
++
+
O
-
O
o
--
--
+
+
Use of Intramural Workforce
O
+
+
+
O
o
+
+
+
EFFICIENT USE OF AGENCY RESOURCES
Multimedia Approach
0
0
0
o
+
o
o
++
++
Priorities
++
++
O
O
+
o
0
+
+
Functional Alignment
+
•f
O
O
O
0
+
0
--
o
(Q
o
1
o
+
+.
++
-
o
0
--
Facilities and Equipment
O
+
O
+
0
o
o
-
Future Investments
O
+
O
+
0
o
o
--
Locus of Control
O
0
+
+
•f
++
o
o
o
Human Resources
O
+
0
+
o
++
-
o
-
IMPLEMENTATION
Implementation Time
O
-
O
-
-
--
o
-
-
--
Implementation Cost
-
0
-
-
--
0
--
o
-
o
--
oo
to
Explanation of symbols: -- strongly negative - negative
Note: The relative Importance among the criteria was not considered In the analysis.
o no effect
+ positive
++ strongly positive
-------
Strongly negative effect: This may mean greatly increased costs (as with some
of the consolidation options) or a strong effect on an important aspect of
operation of the laboratories (e.g., separation of laboratories from customers).
Negative effect: This indicates some negative results are associated with the
option. It also may indicate that there are both negative and positive effects but
that the negative effects are greater.
o Neutral, or no effect: The major use of this symbol is to indicate that there are
no effects and that there is no change from the current situation. There may be
slight either positive or negative effects, but they are not considered strong
enough to warrant a - or +. It also may be used to indicate that the slight
positive and negative effects balance.
+ Positive effect: The overall effects of implementing this option are positive. If
there are slight negative effects, they are outweighed by the positive.
-H- Strongly positive effect: The positive effects greatly outweigh any negative
ones. This indicates a great change for the better from the current situation at the
laboratories.
83 ANALYSIS OF OPTIONS
The five options defined in Section 7 will be discussed in this section. Table 8-1
shows the results of the analysis. Only the major points are discussed under the Strengths
and Weaknesses for each option.
8.3.1 Customer Orientation
Strengths
• Emphasis on customer satisfaction
The increased customer satisfaction would be gained by greater administrative
control on the part of the customers. Since the ORD laboratories would be
placed under the customers for whom they do most of their business, they would
be more responsive to these customers. The program office laboratories are now
under their customers so there would be no change in their status. With
consolidation, these gains would be partially offset by decreased access.
8-3
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• Increase in focus on mission and highest priorities of the Agency
The direct link to the program offices would enhance knowledge and execution
of Agency priorities, especially hi the present ORD facilities. The program
offices and ESO facilities are more focused on their priorities now, so this would
not be as much of a change.
Weaknesses
• With consolidation, large costs
As with any of the options that include physical consolidation, costs in time and
disruption to present programs as well as financial costs would be large.
• With consolidation, negative effects on the ESOs
Consolidation would adversely affect the ESO because some of them would be
taken away from their customers, who are now satisfied with the service they
receive.
The analysis of the Customer Orientation option hinges on the major attribute of the
option, transfer of control of the laboratories to appropriate program offices. The
Customer Orientation with consolidation assumed convenient consolidation of laboratories
that are already hi close physical proximity. The strongly positive evaluation for this
option of the criterion of customer satisfaction reflects the increased ability to determine
customer needs and expectations with direct control by the customer program office.
Although customer satisfaction is still improved with consolidation, it is less because than
without consolidation because of the consolidation of the ESOs assumed under this option.
Since their customers are now very satisfied, the change from the current situation would
cause some discontent. The strongly positive evaluation on the priorities criterion reflected
the expectation that the implementation of this option would increase the focus on those
issues that were most important to the Agency.
83.2 Streamlining
Strengths
• Reduction in operating costs and redundance
Numbers of non-supervisory scientific personnel probably would not be reduced,
but other Grade 14 and above personnel might be.
8-4
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More administrative control at local level
Because most of the reductions in personnel would occur at ORD Headquarters,
day-to-day operations at the laboratories would be under the control of local
administrators and scientists.
• Savings from consolidation allow for creation of administrative and support
specialists
One of the major concerns voiced by many of the scientists was that they spent
more of their tune administering contract that performing science. With
consolidation, more specialists positions could be created to deal with contract
administration, freeing scientists to pursue their own specialties.
• Better use of staff and equipment
The use of the intramural workforce would improve, since removal of layers of
middle management would increase efficiency. Because laboratories are, in many
instances, pursuing similar types of research, they have similar types of
equipment. With physical consolidation, the scientists and technicians would be
more concentrated and expensive equipment with have greater usage.
Weaknesses
• With consolidation, high implementation costs and disruption
As with all of the consolidation and relocation suboptions, the high
implementation costs and the great disruption resulting from the changes would
be a major disadvantage.
• With consolidation, decline in customer satisfaction due to laboratory closings
The laboratories would no longer be serving some of their traditional customers
(e.g., states) if they were closed or moved. If environmental services laboratories
were consolidated, their customers, who tend to be very satisfied, might not
receive the type of services they are accustomed to.
Both of the Streamlining suboptions—without and with physical consolidation—were
judged to be the same on about half of the criteria. The with-consolidation suboption
showed more improvement in the criteria related to costs. Under the physical-
consolidation suboption, the scientific and technological work would be consolidated into
8-5
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fewer facilities, and the staff would be in closer contact with staff of the same disciplines.
This suboption had large implementation costs.
8.3.3 Carnegie Commission
Strengths
• Increase in mission focus, better grasp of priorities, and improvement in locus of
control
The reorganizations proposed by the Carnegie Commission, whether functional
or physical, would sharpen all of these. Under both suboptions, the effects on the
priorities criterion are expected to be positive because of issue-based planning
and because one person, the National Director, is assumed to be responsible for
setting the research agenda. The on-site administrators are assumed not to be
scientists, which the present directors are.
• With consolidation, increase in functional alignment and elimination of
redundancies
With physical consolidation, there is a potential for elimination of functional
redundancies in the new national labs and clearer organizational responsibilities.
• With consolidation, more laboratory-level administration
This would be true whether the director of the consolidated laboratories were at
ORD Headquarters or in the field.
• With consolidation, lower long-term facilities and equipment costs
Higher use of existing equipment and a reduction in the number of facilities
would lead to long-term reductions in facilities and equipment costs.
Weaknesses
• With physical consolidation, large costs and disruption
The disruption from functional consolidation would be less, but there would be
some. Costs from functional consolidation would be negligible. Because of the
large amount of relocation required, this would be an extremely disruptive and
costly option.
8-6
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• Without consolidation, addition of an additional layer of bureaucracy
This would increase operating costs and decrease efficiency in ORD.
This option also has two suboptions, but they are judged to be more different than
under the Streamlining option. The without-consolidation suboption has no strong
positives or negatives, and this option is judged to be neutral on most of the criteria. With
physical consolidation, mission focus, concentration of resources, and functional alignment
would be greatly improved. Without consolidation, operating costs would increase because
of the added layer of bureaucracy.
83.4 Distinct Environmental Services Organization
Strengths
• Increased stature and focus on specific services
Recognition of the importance of technical assistance and services at the
Headquarters level will add to the stature and credibility of the service
laboratories and a national focus can be directed to specific areas of expertise
within the laboratories.
• With consolidation, increase in concentration of resources
Specialists in techniques would be brought together to share resources and
functional redundancies would be reduced. This would result in higher use and
of facilities and equipment and greater efficiency.
• With consolidation, cost savings
Operating costs and future investments would be lower with consolidation. An
Assistant Administrator with a national view could optimize investment decisions
over fewer facilities
Weaknesses
With consolidation, large costs and disruption
Administrative costs and physical disruption would result from implementation.
8-7
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• Customer dissatisfaction from separation from the current administrative
structure
Under either of the suboptions, great customer dissatisfaction would probably
result from the new administrative separation from the customers. Customer
satisfaction is one of the strong points of the current ESO structure, and
implementation of this option would damage that.
• Weakening of current close ties to customers in the regions.
With centralized direction, these ties would not be as strong.
• With consolidation, fewer laboratories, with loss of access to familiar locations
Environmental services staff have worked within a geographical area and have
become familiar with its particular problems, e.g., Region 4's work on mercury
in the Everglades. Although this work could continue, it is likely that the team
that is most familiar with problem would not remain intact.
This option, which would provide for representation of the environmental services
organizations in EPA Headquarters, was judged to have no strong positive attributes and
one strong negative attribute. Although there would be the ability to make national-level
decisions and allocations of work, many of these same decisions are now being made
within program offices and regions. As a result, only a limited number of positive effects
would result from the implementation of this option without consolidation. The stature of
the scientific and technological functions would be raised by attention at Headquarters as
well as the national mission focus. The option was seen as positive for eleven of the with-
consolidation criteria, but was judged to be strongly negative for customer satisfaction,
one of the major issues discerned in the interviews at the laboratories. As with the other
consolidation suboptions, its implementation would entail costs and disruption.
8.3.5 Geographic Location
Strengths
With implementation of place-based approach to environmental management,
increased emphasis on multimedia activities
Under the place-based approach for ecosystem protection EPA would integrate
ecosystems management with strategic planning, budget reform, streamlining,
and reinvention.
8-8
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• Focus of research on a particular geographic area
Specialists on a particular geographic area would be concentrated in the area.
Because of the proximity, more work would be done on environmental problems
in that area.
• With relocation, enhanced geographical access
Researchers would be closer to their geographic area of specialization
• Closer access to customers, yielding increased satisfaction
Customers would be in closer contact with the scientists who were working with
them and be able to provide close direction.
Weaknesses
• With relocation, large costs and disruption
This option has the potential for great administrative and physical disruption over
a long time. The disruption would be greater than for consolidation under some
other options, since new areas of specialization would be established.
• With relocation, duplication of investment from an increased number of facilities
Operating costs and future investment costs would increase because of the costs
of starting and maintaining a greater number of laboratories.
• With relocation, more people needed to provide critical skills
The creation of the new provincial laboratories would require more people.
The Geographic Location option was evaluated both without and with physical
relocation. Assuming a place-based approach, both suboptions are strongly positive for
having a multimedia approach. Under this assumption, the focus on the mission and the
priorities of the Agency would increase, a major change resulting from the emphasis on
work pertaining to a specific geographic location. The without-relocation subotion is
neutral for the cost criteria, since the there would be only administrative changes at the
laboratories. In contrast to the consolidation suboptions, this suboption calls for more, not
fewer, new facilities. With these new facilities, costs would increase, resulting in a
strongly negative evaluation for the cost criteria.
8-9
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8.4 ANALYSIS OF CRITERIA
As shown in Table 8-1, the effects of the options are more clearly discrimination by
only some of the criteria. In this section, all the criteria are discussed in relation to the
options.
8.4.1 Criteria for Effective Use of Agency Resources
• Science Quality/Utility: None of the options inherently produce science of a
higher quality or utility than others, although some may favor it. This criterion
had very little discriminating power among the options. Options that brought
together scientists of like interests, such as Carnegie Commission and DESO
with consolidation and Geographic Location without and with relocation, were
evaluated more highly than other options on this criterion.
• Stature/Credibility: All the options, except the Carnegie Commission and
DESO, were evaluated as neutral on this criterion. Because of the raising of- the
laboratories to national status, the effects of implementing the Carnegie
Commission DESO options, both without and with physical consolidation, were
evaluated as positive.
• Concentration of Resources: All the options that contained consolidation or
relocation were evaluated positively on this criterion. This suboptions would
concentrate scientific and technological resources, both staff and equipment, with
the expected result of increasing interactions, information transfer, and use of
equipment among staff. Since the Carnegie Commission with consolidation
option would provide the most concentration, this was given a strongly positive
evaluation.
• Geographic Location: All the options were evaluated to be neutral on this
criterion, with the exception of DESO with consolidation (negative) and
Geographic Location with relocation (strongly positive). Part of the neutrality
was the result of the assumption that the ORD and program office facilities
would remain open as field stations even with consolidation. If these facilities
were eliminated, then there would be more negative evaluations for this criterion.
The DESO with consolidation suboption was negative because, in this case, some
laboratories would be eliminated, thus losing one of the major positive aspects of
the environmental services organizations, their closeness to their customers. The
Geographic Location with consolidation suboption was evaluated to be strongly
positive because more laboratories would be opened to be more closely tied to
8-10
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specific geographic areas, as well as because of assumed implementation of the
place-based approach to ecosystem protection.
• Mission Focus: Sharpening the focus on the mission of the ORD laboratories
would be one of the major advantages of the Carnegie Commission and DESO
options, especially the with-consolidation suboption. This criterion is also
positive for both suboptions of the Customer Orientation option, because the
mission focus is one of the major aspects of this option. Streamlining is not
directed toward this criterion, and the ESOs are already focused on their
missions.
• Customer Satisfaction: Major emphasis has been placed on customer
satisfaction during the executive interviews and at the laboratories, and this
criterion provides for discrimination among the options, with the full range of
possible evaluations. While the evaluation for the Customer Orientation option,
both without and with consolidation, was positive, the greater benefits were seen
to be derived without consolidation. Although the overall effect would be
positive, consolidation would negate some of the benefits gained through its
negative effects on the ESOs. The strongest negative effects would be seen in the
DESO option, because it would adversely affect relationships with the ESO
customers because of the separation brought about by this option. Under the
Geographic Location option, customer relationships would be realigned, but an
overall improvement would be expected as facilities become attuned to the needs
of their new customers.
• Use of Intramural Workforce: Options were generally evaluated as neutral
without consolidation and positive with consolidation for this criterion. An
exception was Streamlining, which was positive for both suboptions. The effects
of consolidating the workforce were considered to be positive.
8.4.2 Criteria for Efficient Use of Agency Resources
Multimedia Approach: This criterion had effects on only the Carnegie
Commission and Geographic Location options; it was neutral for all the other
options. For the Carnegie Commission option, a greater ease of coordination
among multimedia teams would result from fewer administrative leaders. Both
susboptions of the Geographic Location option were evaluated as strongly
positive for this criterion, resulting from the multimedia aspects of the assumed
implementation of the place-based approach to ecosystem protection.
8-11
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Priorities: None of the options were seen as being negative for this criterion; all
were neutral or positive. This is closely related to mission focus, since better
focus on the mission would enable the priorities to be directed to the mission.
The Customer Orientation option was strongly positive for this criterion, since
the direct link to the program office customers on the part of ORD would ensure
that program priorities were met.
Functional Alignment: Both strong negatives and strong positives were seen on
this criterion. The strong positive was for the Carnegie Commission with
consolidation. One of the goals of this suboption is to provide function alignment
for the ORD laboratories, and, to the degree that that goal is successful, the
suboption is successful. The Geographic Location with relocation suboption is
evaluated as strongly negative because of the redundancy of the new provincial
facilities and duplication of basic services.
Operating Costs: With the exception of the Geographic Location with relocation
suboption, operating costs improve with consolidation, especially so under
Streamlining with consolidation. Consolidation provides for more efficient use of
both staff and equipment resources. Operating costs would increase under the
Carnegie Commission without consolidation, because this would add a layer of
administration in ORD.
Facilities and equipment: This criterion provides very little discrimination
among the options. All options without consolidation or relocation are evaluated
as being neutral, and all options with consolidation are evaluated as being
positive. The Geographic Location suboption, with relocation, is negative
because it requires construction of new laboratories.
Future Investments: As with facilities and equipment, this criterion provides
little discrimination among the options. For all the options except Geographic
Location, the suboption without consolidation is neutral and the suboption with
consolidation is positive. This reflects higher use of existing equipment and the
reduction in the number of facilities with consolidation and the lack of change
from the current without consolidation. The strong negative evaluation for
Geographic Location reflects the investment required for new laboratories.
Locus of Control: This was one of the few criteria where the presence or
absence of consolidation generally did not make a difference in the evaluation of
the option; except for DESO, both suboptions were in the same direction. The
positive evaluations were based on the probability that implementing the option
would result in increased administrative authority at the local level, especially in
8-12
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the Carnegie Commission with consolidation suboption. The difference in the
evaluation of the DESO suboptions reflected the lack of increase in local control
in the present unconsolidated ESOs (they already have local control) and the
increase in local control with consolidation.
• Human Resources: This criterion provides little discrimination most of the
suboptions without physical consolidation are evaluated as neutral and most of
the suboptions with consolidation are positive. The DESO is negative because of
the additional resources required for the Assistant Administrator position at EPA
Headquarters. Geographic Location with relocation is negative because of the
additional personnel required at the new provincial laboratories.
8.43 Criteria for Implementation
• Implementation Time and Cost: These two criteria are considered together
because their evaluations are similar. There were no positive evaluations for any
option because of the changes required; the best evaluation any option received
was neutral. (EPA is preparing a cost analysis of consolidation and relocation
options.) The Carnegie Commission with consolidation and the Geographic
Location with relocation suboptions were evaluated as strongly negative on both
these criteria because of their high costs hi both time and money. Such aspects
of consolidation as buying out leases, moving personnel, and loss of personnel
who choose not to move would be high. Disruption of moving would also be
costly hi terms of morale and changes to programs.
8.5 SUMMARY
Since the Carnegie Commission option affects only the ORD laboratories, and the
DESO option affects only the ESOs, these options should not be be compared but could
be combined.
Among the positive aspects of the options, the Carnegie Commission option with
physical consolidation was evaluated more favorably than any of the other options that
involve ORD. In the areas hi which the Carnegie Commission with consolidation
suboption was strongly positive—human resources, mission focus, locus of control,
functional alignment, and concentration of resources—none of the other options that
would affect the ORD laboratories was as positive.
The strongly positive aspects of the Geographic Location option, i.e., its multimedia
approach resulting from place-based ecosystem protection, could be implemented under
8-13
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other structural options as well. This is true also of the strongly positive aspects of the
Customer Orientation option, customer satisfaction and focusing on the highest priorities
of the Agency.
The Streamlining option was essentially neutral for the criteria, although it was the
only option that provided large cost savings. If the provisions of this option were
implemented under either the Carnegie Commission or DESO option, these savings could
be effected.
The evaluation of the DESO option showed it could have positive effects on the
stature of the laboratories and the mission focus, although it is strongly negative with a
large loss in customer satisfaction, an area in which the ESOs are now highly rated. With
consolidation, some savings would be seen in operating, facilities, and equipment costs,
and other benefits are offset by the decline in customer satisfaction. Geographic Location
would provide improvements hi the area of customer satisfaction, where the DESO option
was very weak.
The option judged most to be most negative, Geographic Location widi relocation,
would affect all three types of laboratories. This option was evaluated as strongly negative
for functional alignment—a criterion for which the Carnegie Commission option with
consolidation was judged strongly positive. The difference hi the evaluation was based on
the nature of the consolidation, which was functional in the case of die Carnegie
Commission and geographical for the Geographic Location option. The alignment
resulting from the Geographic Location option was seen as expensive and not productive;
it was seen as having the negative aspects of relocation—disruption and high costs—and
few of the advantages of die Carnegie Commission option.
The implementation costs, in both time and money, were high for all consolidation
and relocation options. For two suboptions—Carnegie Commission without consolidation
and Geographic Location widi relocation—the potential administrative disruptions were
considered to be very high. The large costs involved would be a strong impediment to the
full implementation of these options.
8-14
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SECTION 9
OTHER FEDERAL MODELS
A brief examination has been made of three federal agencies—the U.S. Food and
Drug Administration (FDA), the NTH, and the U.S. Nuclear Regulatory Commission
(USNRC)—to gain a sense of how these agencies deal with the performance of quality
scientific and technological functions that directly or indirectly support regulations,
planning and priority setting, acquisition and management of extramural support, and
inherently government functions. Like EPA, these three agencies must maintain a long-
range research competence while fulfilling the near-term needs of their internal regulatory
customers, external regulated organizations, and other stakeholders such as the public and
the scientific and technological community at large. The three agencies were chosen
because they represent different approaches to science and technology relevant to
regulation. While EPA may want to consider reviewing additional agencies, these three
provide a range of useful information to the EPA laboratory study regarding different
management approaches to the practice of regulatory science. For instance, the USNRC
has no intramural research laboratories, while the FDA maintains an extensive intramural
laboratory system and devotes only a small percentage of its funding to extramural
research. In contrast, the NTH maintains a substantial intramural program yet invests the
majority of its funding in an extramural grant program. A summary of these agencies is
presented in the following sections.
9.1 U.S. FOOD AND DRUG ADMINISTRATION
9.1.1 Mission
FDA is a science-based regulatory agency. The scope of FDA regulatory responsibility
is extremely broad and highly diverse, and it principally serves the general public in its
health and safety mission. More specifically, FDA's regulatory responsibilities focus on
safeguarding the following public interests:
• Foods (excluding most meat and poultry products) are safe, wholesome, and
sanitary; human and veterinary drugs, human biological products, diagnostic
products, and medical devices are safe and effective; cosmetics are safe; and
radiation-emitting electronic products are safe.
Regulated products are honestly, accurately, and informatively advertised and
labeled.
9-1
-------
Regulated products are in compliance with FDA regulations and guidelines,
noncompliance is identified and corrected, and any unsafe or unlawful products
are removed from the marketplace.
9.1.2 Science Base
Science underpins FDA's regulatory activities. The knowledge and capabilities of its
scientific staff are integral to product review, surveillance and compliance, problem
analysis, consumer education, and other responsibilities. FDA scientists directly support
regulatory decisions by assessing risks associated with FDA-regulated products, setting
standards that contain risk, testing products against those standards, improving the
usefulness and precision of risk assessment methods, and developing methods to increase
the accuracy of sample analysis and detection of chemicals and biological substances.
FDA depends on science to support four of its primary functions:
• Provide a sound basis for regulatory decisions: FDA scientists develop
answers to scientific and technological questions that are vital to the safety and
effectiveness of regulated products and manufacturing processes. These questions
encompass such diverse research and regulatory activities as methods
development, product testing, hazard determination, enforcement tolerances,
standard setting, risk assessment, and support for new technologies. In addition,
FDA scientists participate in research to extrapolate animal health data into
relevant human terms and serve on committees designed to forge a consensus
concerning the scientific principles that may be used as a basis for risk
assessment.
• Stay current with advancing science and technology: FDA's scientific
expertise enables it to assess new products and technology, to advise sponsors on
the design of clinical trials, and to detect weaknesses in safety and effectiveness
data. For example, FDA research in pharmacokinetics has greatly enhanced the
program knowledge of drug delivery, optimal dosage levels, bioavailability, and
bioequivalence. The success of such research activities and their applications
depends on the ability of FDA scientists to interact effectively, decisively, and
knowledgeably with their peers in industry.
• Expedite product development: When FDA researchers participate in research
involving design, development, testing, and evaluation of new technologies, they
can offer valuable advice to product sponsors to expedite product testing.
Scientists conducting reviews can also evaluate novel product submissions more
promptly if they already understand the product's mechanisms.
9-2
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• Transfer technology: FDA develops and improves methods that become the
industry (as well as the FDA) standards for the testing and measurement of
regulated products. Examples include development of field instruments in use for
measurements on microwave ovens and diagnostic ultrasound machines.
FDA is being severely challenged to maintain and update its science base. Each year,
hundreds of new drugs and biologicals and 5,000 to 6,000 new and enhanced medical
devices are cleared for marketing. In addition, 10,000 new products appear on American
supermarket shelves, and thousands of new chemicals are introduced yearly. This
continuing introduction of new products requires a broad array of scientific capabilities to
analyze and characterize their composition, detect and assess their risks, and understand
and evaluate their effects within the human body.
9.13 Scientific Organization
The various scientific research activities at FDA are carried out by the following
organizations that are part of the Office of Operations, which is headed by the Deputy
Commissioner for Operations (see Figure 9-1):
• Center for Biologies Evaluation and Research (CBER)
• Center for Drug Evaluation and Research (CDER)
Center for Devices and Radiological Health (CDRH)
• Center for Food Safety and Applied Nutrition (CFSAN)
• Center for Veterinary Medicine (CVM)
• National Center for Toxicological Research (NCTR)
The Senior Advisor for Science advises the Commissioner on ways to strengthen and
improve the quality of science and scientific research at FDA. To assist the Senior
Advisor in this capacity, three groups have been established:
Science Board to the FDA: A standing advisory committee of experts from
academia and industry who specialize in the scientific disciplines relevant to
FDA
• Senior Science Council: One senior scientist from each FDA center and the
Office of Regulatory Affairs; established to advise the Senior Advisor for
Science on science issues throughout FDA
Consultants to the Senior Advisor for Science: Two scientists from each FDA
center and the Office of Regulatory Affairs who have worked at FDA between
three and ten years
9-3
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Commissioner
Executive Assistant
Ombudsman
Senior Advisor
Senior Advisor for Science
Office of the
Administrative
Law Judge
Office of Executive
Operations
Office of Equal
Employment
Opportunity and
Civil Rights
Deputy
Commissioner for
Operations
Deputy
Commissioner for
Policy
Deputy
Commissioner for
External Affairs
Deputy
Commissioner for
Management and
Systems
- Center for Biologies
Evaluation and Research
-Center for Drug Evaluation
and Research
Center for Devices and
Radiological Health
- Center for Food Safety and
Applied Nutrition
- Center for Veterinary Medicine
- National Center for
Toxlcologlcal Research
Figure 9-1. Organization Chart for the U.S. Food and
Drug Administration
-------
The Council and Consultants have made recommendations regarding staff development,
recruitment and retention, and enhancement of FDA's scientific infrastructure.
9.1.4 Program Management
FDA relies heavily on the Program Management System (PMS) for conducting its
scientific research activities. It has been used for planning, budgeting, reporting, and
evaluation by the Agency since 1971. Programs and projects are the basic pieces that form
the PMS. A framework of six programs form the foundation of the PMS. The majority of
programs—Animal Drugs and Feeds, Biologies, Food and Cosmetics, Human Drugs, and
Medical Devices and Radiological Health—follow the major product categories for which
the Agency is responsible. The one exception is the NCTR program, which represents a
specialized capability to address regulatory concerns that affect all product areas. These
six programs are subdivided into 30 projects that form the basic building blocks of the
structure. The projects in each program represent important areas of emphasis.
The PMS structure is extensively used for strategic planning, operational planning,
budget allocation, and budget execution. Each phase of the process relies on the PMS
structure so mat from year to year, the details of program and project areas are closely
linked to the fundamental activities of die Agency. During the yearly planning process,
the structure serves as a basis for program planning. Proposals for changes in programs
can be assessed based on their possible impact on project activities and objectives.
Program managers throughout FDA also use the structure each year for the operational
planning of field resources, including the activities of the field offices and laboratories.
Finally, the PMS structure serves as the basis for preparation and submission of plans and
budget requests through the Executive Branch and Congress, as part of the annual budget
cycle. The structure provides the basis for the allocation of portions of die total funding
request to the Agency's programs and projects. The President's Budget contains a table
that depicts the allocation of FDA resources by PMS programs and projects.
9.1.5 Resources and Constraints
In spite of its critical regulatory responsibilities and impacts, FDA has some resource
constraints that are discussed below:
Funding: In the last ten years, significant new responsibilities have been added
throughout FDA as the result of die enactment of 31 new laws. In almost all
cases, the new legislation added new responsibilities, but the funds required to
implement them were either not provided or inadequate. Thus, FDA has been
coping with rising responsibilities by reprogramming resources to new, high
priorities. Over the same period, there has been a decline on the order of
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10 percent in FDA's staffing level for areas such as foods, animal drugs, and
critical infrastructure. In contrast to EPA, FDA devotes a very small percentage
of its budget to fund extramural contractors. In five of the six PMS program
areas, contractor employees constituted only 1 to 6 percent of the total in FY93.
The only exception is the NCTR program, which allocated 58 percent (332 out
of 571) of its FTEs to various contractors. Tables 9-la through 9-lc summarize
the Agency*s current resources in terms of workforce numbers and dollars.
Staffing: FDA, along with other science-based federal organizations, faces severe
competition for qualified scientists, engineers, and physicians. FDA may have
difficulty competing in this labor market for certain critical shortage categories
because its salary level average is well below that of industry. Low pay and poor
working conditions have already led to periodic high turnover in some
occupations. A 1989 General Accounting Office (GAO) study found that the
turnover rate for FDA biologists was four times higher than the federal
government average, and turnover in pharmacologist positions was twice as high.
In addition, FDA faces staffing challenges because its work force is aging. The
average age of FDA staff in 1992 was 46.5 years, and about half of FDA
managers will be eligible to retire by 1995.
Facilities: FDA's facilities in the Washington, D.C. area are widely scattered in
40 buildings in 15 separate locations. Many headquarters and field facilities,
especially laboratories, are old, outdated, and inadequate for FDA's needs. FDA
is currently the only Public Health Service (PHS) agency lacking complete
accreditation from the American Association for the Accreditation of Laboratory
Animal Care of all its laboratories. A General Services Administration
(GSA)-directed study of FDA's facility needs in FY90 confirmed the inadequacy
and inefficiency of FDA's headquarter facilities. FDA's field facilities are as
seriously inadequate as its headquarter facilities. The need to update obsolete
facilities has sharply increased FDA's facility costs, which are the fastest
growing item in FDA's budget. FDA's facility costs increased over 100 percent
from FY87 to FY93 (a time period when FDA's staffing increased 29 percent).
Facility costs now account for over 10 percent of FDA's budget.
Equipment: FDA depends on its laboratory equipment to give rapid and reliable
results in laboratory analyses ranging from detecting pesticide residues or
microbiological contamination to investigating tampering incidents with forensic
drug analysis. FDA annually identifies and allocates funds in the planning and
budgeting cycle to maintain existing equipment and replace worn-out and
obsolete equipment. However, due to past budget constraints, funding for proper
maintenance and replacement has often been reduced. As a result, equipment has
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Table 9-la. FDA's FY93 Agency FTEs by Program and Strategic Area
Program
Biologies
-luman
Drugs
Devices
Foods
Animal
Drugs/Feeds
NCTR
Program
Management
TOTALS
PCC
Strategic Area
Pre-Market
Review
359
1,335
418
155
148
34
22
2,471
-
Post-Market
Assurance
289
847
753
1,925
221
-
100
4,135
-
Food
Safety
-
-
-
112
19
16
2
149
-
International
Harmonization
11
11
24
5
2
1
25
79
-
Information
Systems
26
70
76
49
10
10
41
282
120
Science
Base
164
61
170
473
38
85
4
995
-
Organization/
Management
50
60
51
34
54
13
45
307
-
People/
Faci I/Equip
36
32
79
20
4
80
123
374
-
Appropriated
FTE Total 11
935
2,416
1,571
2,773
496
239
362
8,792
120
Contract
FTEs2/
61
90
10
50
13
332
651
-
TOTALS
996
2,506
1,581
2,823
509
571
362
9,348
-
I/ FY 1994 Volume XII Justification of Estimates for Appropriations Committees, pg. 2. FY 1993 total was 9,053 FTE including salaries
and expenses, and other accounts.
21 Contract FTEs based on FY 91 data.
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Table 9-lb. FDA's FY93 Agency Dollars by Strategic Area
Funding Type
Staff Expenses
Variable Operating
Costs I/
Capital Infrastructure 21
TOTALS
Strategic Area
Pre-Market
Review
158,144,000
44,768,000
16,307,000
219,219,000
Post-Market
Assurance
264,640,000
74,915,000
27,288,000
366,843,000
Food
Safety
9,536,000
946,000
344,000
10,826,000
International
Harmonization
5,056,000
501,000
182,000
5,739,000
Information
Systems
18,048,000
6,185,000
2,253,000
26,486,000
Science
Base
63,680,000
21,824,000
7,949,000
93,453,000
Organization/
Management
19,648,000
1,947,000
709,000
22,304,000
People/
Facil/Equip
23,936,000
8,203,000
2,988,000
35,127,000
TOTALS
562,688,000
159,289,000
58,020,000
779,997,000
oo
Table 9-lc. FDA's FY93 Agency Dollars by Program
Funding Type
Staff Expenses
Variable Operating Costs I/
Capital Infrastructure 21
TOTALS
Program
Biologies
59,840,000
27,885,000
10,157,000
97,882,000
Human Drugs
154,624,000
44,103,000
16,064,000
214,791,000
Devices
100,544,000
18,976,000
6,912,000
126,432,000
Foods
177,472,000
30,964,000
11,279,000
219,715,000
Animal
Drugs/Feeds
31,744,000
7,480,000
2,724,000
41,948,000
NCTR
15,296,000
13,256,000
4,829,000
33,381,000
Program
Management
23,168,000
16,625,000
6,055,000
45,848,000
TOTALS
562,688,000
159,289,000
58,020,000
779,997,000
I/ Includes: relocation, travel, transportation, service contracts, materiaJs/supplies, equipment replacement costs, and extramurals (including $5.8 million
in ORA contracts for state inspections).
21 Includes: rental payments, buildings and facilities, communications, utilities, printing, selected central accounts, and PC&B in service contracts.
-------
not been operated efficiently or been replaced on a systematic schedule. Much FDA
equipment is approaching obsolescence. In the CFSAN alone, more than 50 percent of
scientific equipment is obsolete. In FDA overall, about 70 percent of the $167.2 million
laboratory equipment inventory is scheduled for replacement by the year 2000, but tight
budgets are likely to constrain needed funding.
9.1.6 Strategies for the Future
FDA managers realize that it will be difficult at best to acquire additional resources
through appropriated funding. In light of this situation, the following strategies have been
designed to maximize the use of existing Agency resources in the area of scientific
research.
• Improve research planning and coordination: The Agency plans to conduct
regular research program peer reviews to address both the quality of the science
and its relevance to the Agency's regulatory needs. These review programs are
being expanded to identify opportunities for improved efficiency or joint research
with other components of the Agency or with outside organizations. FDA is
working to fully coordinate access to scientific expertise in support of research
and decision making.
• Enhance recruitment and staff development: The Office of the Senior Advisor
for Science has established two internal groups to address science issues across
the Center, including recruitment and retention of scientists and staff
development. The recommendations they have made include: establishing a
post-doctoral fellowship program, holding annual awards for excellence in
science, and coordinating recruitment by job types, rather than by Center.
Programs for professional development of scientists are being expanded. One
approach is the use of a Staff College that is comprised of in-house, academic
training programs.
Promote interactions with outside organizations: Through the Interagency
Personnel Act, FDA scientists can benefit from sabbaticals outside the Agency
and from the expertise of researchers from academia or industry who are
working in FDA laboratories. These exchanges may last from six months to two
years. The Office of the Senior Science Advisor will establish an Agency-wide
Science Scholar Program through the opportunities presented by this Act. FDA
plans to further pursue targeted, cooperative efforts with other agencies, industry,
and academia to facilitate the development and introduction of safe and effective
new product technologies. Such collaboration can generate the critical mass
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needed in areas of emerging technologies and can be a cost-effective way to
leverage FDA's limited science resources.
Consolidate research programs and facilities: FDA is assessing ways for
consolidation of some programs and combination of some technical resources so
that it may build a critical mass of research in areas of growing importance. In
addition, the Science Board to the FDA, an Office of the Commissioner advisory
committee, will examine the proper role of research in the Agency, the relevance
of current research programs, and methods for improving these programs. FDA
plans to consolidate and co-locate headquarters facilities hi two locations in
suburban Maryland at a projected expense of $825 million.
9.2 THE NATIONAL INSTITUTES OF HEALTH
The NIH is the steward of biomedical and behavioral research for the nation. As such,
it is broadly responsible for research into the pathogeneses or processes that might impair
health and the implementation of approaches to modify untoward outcomes. The NIH
carries out biomedical research through its intramural program located in Bethesda,
Maryland and a few additional sites around the country. It also is a major granting agency
for research at institutions of higher learning throughout the country. A great deal of
university biomedical research is funded through such NIH research grants. The NIH, as
its name implies, consists of several individual institutes, each with its own organizational
structure. Institutes have their own intramural programs and also administer their own
grants, contracts, and training programs. The NIH Director serves primarily as an overall
supervisor of NIH activities and as a liaison with the Department of Health and Human
Services (HHS) and the community. Until recently, essentially all research was funded
through the individual institutes, administered by their individual institute directors.
Recently, the NTH Director has been allocated a substantial amount of money for directed
research efforts.
9.2.1 Mission
The mission of the NIH, according to NIH Manual 1125 of September 1993, is
science in pursuit of fundamental knowledge about the nature and behavior of living
systems and the application of that knowledge to extend healthy life and reduce the
burdens of illness and disability. The following have been identified as goals of the NIH:
• Foster fundamental creative discoveries, innovative research strategies, and their
applications as a basis to advance significantly the nation's capacity to protect
and improve health
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• Develop, maintain, and renew scientific human and physical resources that will
ensure the nation's capability to prevent disease, improve health, and enhance the
quality of life
• Expand the knowledge base in biochemical and associated sciences in order to
enhance the nation's economic well-being and ensure a continued high return on
the public investment in research
• Exemplify and promote the highest level of scientific integrity, public
accountability, and social responsibility in the conduct of science
In realizing these goals, the NIH provides leadership and direction to programs
designed to improve the health of the nation by conducting and supporting research in the
following areas:
• The causes, diagnosis, prevention, and cure of human diseases
• The processes of human growth and development
• The biological effects of environmental contaminants
• The understanding of mental, addictive, and physical disorders
• The collection, dissemination, and exchange of information in medicine and
health, including the development and support of medical libraries and the
training of medical librarians and other health information specialists.
Thus, the broad mission of the NIH relates to the health of the nation. Nevertheless,
its mission is largely distinct from that of other arms of its HHS parent agency (e.g.,
Medicaid) or of other agencies dealing with aspects of health. With regard to the latter, it
is largely excluded from the responsibilities delegated to related regulatory agencies such
as the FDA, EPA, the Centers for Disease Control and Prevention (CDC), and the
Occupational Safety and Health Review Commission (OSHRC). There is, however, some
overlap between EPA and NIH, between CDC and NIH, between FDA and NIH, and
between OSHRC and NTH. There is also health-related research funded by CDC, FDA,
EPA, the Department of Defense, the Department of Energy (DOE), and other arms of the
federal government.
The NIH mission is, perhaps, most evident in the realm of clinical and basic research
directed at the understanding of disease pathogenesis. This includes detailing basic
molecular mechanisms underlying normal physiology and cell biology as well as
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abnormalities of those mechanisms which may lead to disease. Such understanding leads
to new approaches to diagnosis and therapy, and ultimately, prevention.
9.2.2 Organization and Funding
The NIH is organized primarily into individual institutes with broad responsibilities for
funding and carrying out research in specific areas (Figure 9-2). The NIH primarily
supports research through (1) direct intramural funding, (2) a granting mechanism to
support extramural scientists (usually at universities), and (3) contracts to support directed
research efforts. This support is divided among various program areas administered by
individual institutes. Each program area decides if proposed research falls within its
institute's individual mission or missions.
The overall funding for NIH and the recipients of this funding are shown in Table 9-2.
Based on the 1992 estimate, NIH received about two and a half times as much money for
health research and development as all other federal agencies combined; the projections
for 1993 (not shown) indicate that NIH's share of funding was more than four times-that
received by all other federal agencies. The government provides funds for research in
institutions other than those of the federal government. Thus, as Table 9-2 illustrates,
much research is performed outside of government. Table 9-3 shows the allocation of NIH
funds by performers of the health-related research. Much more money is allocated to
support university research than to support intramural research. Non-industry research is
primarily funded by the NIH and primarily performed at institutes of higher learning.
Table 9-4 represents the NIH obligations for 1992. The majority of funds were
obligated in the area of research grants. The two next greatest were intramural research
and development contracts. Approximately 5 percent of funds was used in research
management and support.
The locus of control of support for specific activities at the NIH resides in the
individual institutes. The institute director provides overall supervision of all activities
within the institute. Intramural research is usually administered by the Director for
Intramural Research of each institute. Institutes and programs within institutes often
differmarkedly in the degree of high level control of individual research efforts. In
practice, much research planning is done by individual investigators with only general
programmatic control by their superiors. However, the superiors usually exercise strict
budgetary control. The superior can reduce personnel, laboratory space, and budget for an
investigator thought to be doing sub-par work. There is some, but usually much less,
ability to increase space, personnel and budget for investigators doing an outstanding job.
Thus, in the intramural program, the budget and control are closely linked
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Office of the Director
National Institute
on Aging
National Institute
of Child Health
and Human
Development
National Eye
Institute
National Institute
on Alcohol Abuse
and Alcoholism
National Institute on
Deafness and Other
Communication
Disorders
National Heart,
Lung, and Blood
Institute
National Institute
of Allergy and
Infectious
Diseases
National Institute of
Dental Research
National Institute of
Mental Health
National Institute of
Arthritis and
Musculosketal and
Skin Diseases
National Institute of
Diabetes and
Digestive and Kidney
Diseases
National Institute of
Neurological
Disorders and Stroke
National Cancer
Institute
National Institute of
Environmental
Health Sciences
National Institute of
Nursing Research
Note: As a rule, the laboratory functions for the Institutes depleted above are overseen by each Institute's Intramural Research Division.
The National Institute of General Medical Science Is not shown above since It has only extramural programs.
Figure 9-2. Organization Chart for Department of Health and Human
Services, Public Health Service, National Institutes of Health,
Division of Intramural Research
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Table 9-2. National Support for Health Research and Development
(1992 estimate, in $ millions)
Federal Government
National Institutes of Health
Other Federal Government
State and Local Governments
Industry
Institutes of Higher Education
Other Private Nonprofits
Foreign
TOTAL
Sources of Funds
$11,727 (41%)
$8,407 (29%)
3,320 (12%)
1,900 (7%)
13,870 (48%)
1,221 (4%)
$28,718
Research Performers
$2,837 (10%)
544 (2%)
11,370 (39%)
9,279 (32%)
2,481 (9%)
2,205 (8%)
$28,716
Source: NIH Data Book 1993. Basic Data Relating to the National Institutes of Health.
U.S. Department of Health and Human Services, National Institutes of Health.
Table 9-3. 1992 Distribution of NIH Health Research
and Development Funds by Performer
(in $ millions)
Federal Government
State and Local Government
Industry
Higher Education
Other Nonprofit
Foreign
TOTAL
$1,604 (19%)
61 (1%)
378 (4%)
4,982 (59%)
1,335 (16%)
46 (1%)
$8,407
Source: NIH Data Book 1993. Basic Data Relating to the National Institutes of Health.
U.S. Department of Health and Human Services, National Institutes of Health.
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Table 9-4. Distribution of 1992 NIH Obligations
(in $ millions)
Research Grants
Research and Development Contracts
Research Training
Cancer Control
Construction
Intramural Research
Research Management and Support
National Library of Medicine
Office of the Director
Buildings and Facilities
TOTAL
$6,102 (69%)
638 (7%)
310 (3%)
108 (1%)
12
996 (11%)
409 (5%)
99 (1%)
144 (2%)
61 (1%)
$8,879
Source: NIH Data Book 1993. Basic Data Relating to the National Institutes of Health.
U.S. Department of Health and Human Services, National Institutes of Health.
In the extramural program, the institute decides on general levels of funding for
specific programs. The greatest direct control comes through contracts. These are let by
the administrators of the extramural programs of the various institutes. The granting
mechanism provides peer review by outside 'consultants' and so approval of specific
grants is, essentially, outside the strict control of the institute administrators.
The three general mechanisms for funding mentioned above—grants, contracts, and
intramural research—are evaluated somewhat differently. Grants are funded based upon
the results of a peer-review process in which working scientists with intimate domain
knowledge meet to evaluate and grade (by secret ballot) proposals. Only a relatively small
portion (approximately 10 to 20 percent) are funded. Contracts vary in scope and detail. A
contract may be let to a university or a company. The criteria for obtaining a contract are
stringent, and an NIH project officer has overall monitoring responsibility. Each
intramural program uses its own evaluation criteria for program selection. In general, they
hire excellent young scientists and bring their careers along by providing increasing
resources. If the work is excellent, funding continues. Each institute's Director for
Intramural Research is responsible for both clinical and basic research within the institute.
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For evaluation of the effectiveness of a scientist, the director tends to rely on (1) direct
knowledge of the work done, (2) list of publications generated (which can be appraised by
the director who is a working scientist with domain knowledge), and (3) recommendation
of direct supervisors of an evaluated scientist who stand between director and the
individual scientist in the organizational structure.
The expectation of the staff in NIH's intramural research laboratories is that they are
to perform research or provide support to others who are carrying out research. The same
is true of grant recipients in universities. Occasionally, such people are asked to deal with
issues involving regulations of one kind or another; however, the NIH is not preoccupied
with regulations the way FDA is; therefore, this is less of an issue. In the overwhelming
majority of cases, the laboratories produce what is expected of them: good research. In the
intramural program, the laboratories generally receive the support they expect from
headquarters. This is not always the case for individual scientists at universities: many of
them apply for research grants and are not funded. This regularly happens even to good
scientists.
In recent years, there has been increasing pressure from the extramural community for
tighter review of intramural research. This has lead to a greater use of, and attention to,
outside scientific review committees. These committees include high-powered scientists
with domain knowledge of individual aspects of the program. They can recommend
increasing the funding, space, and support staff for outstanding work and contracting or
eliminating less productive scientists or whole laboratories. Although these committees are
only advisory, and often were ignored in the past by the directors, in recent years they are
carrying more and more weight. The Director for Intramural Research of an institute is
now more inclined to follow the recommendations.
9.2.3 Science Base
The NIH has excellent science for the following reasons:
• There is an atmosphere of excellent science which draws outstanding scientists
that is a positive feedback.
• There is a scientific tradition that is built upon. Excellent scientists from
elsewhere feel it is an honor to visit, give lectures, and work at NIH.
• The mission is science. In other words, doing cutting edge work is not something
one does in spare moments or when the boss isn't looking,
• There is funding for good science.
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• There are local professional rewards for good science. In other places, the
rewards may be for program efforts unrelated to cutting edge science.
There are external (peer) rewards for good science (scientists are invited to give
lectures throughout the country or the world, attend desirable meetings, sit on
important committees, etc.)
• Good science is its own reward for inquisitive people who desire new
information. This is a special breed. They do not gravitate towards regulatory
agencies. They want the freedom to push new frontiers their own way.
9.2.4 Administrative Issues
The NIH is able to recruit very talented young scientists into its intramural research
program. Because they must compete for funds with other very talented investigators who
already have carved out their small domains, it is possible for younger scientists to be
under-supported for many years. There are major space limitations in certain units and
also limitations on FTEs. The NIH experiences intermittent job freezes; as a result, it is
sometimes difficult to maintain sufficient high-quality support personnel. The purchase of
large-ticket items by an individual investigator is sometimes hampered by the small size
of a programmatic unit—that small size prevents the flexibility to purchase such large
items from current funds.
There are additional problems with purchasing. Purchasing must be done according to
government purchasing regulations which are designed to assure lowest price and
competitive bids for common off-the-shelf items; these regulations are less suitable for the
purchase of needed biological reagents of high quality.
There also are many administrative successes. Program project grants bring together
several scientists at a single institution so as to (1) pool resources, (2) collaborate
meaningfully, and (3) undertake projects of a breadth or depth not possible by an
individual scientist. The purchase of large items for the intramural program may be
anticipated by high-level administrators who may set aside funds for such a purpose.
Mechanisms are sought for working within government regulations but with the
recognition of the unique needs of the NIH employees. This holds for purchases of certain
biological materials from specific suppliers. Many younger intramural scientists do not
have as much travel money available to them as they would like. Because of the
enormous Bethesda, ME> scientific community and the many scientific visitors, this is less
of a problem for most intramural NTH scientists than would be the case if they were
disbursed.
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93 U.S. NUCLEAR REGULATORY COMMISSION
93.1 Introduction
Prior to 1974, nuclear activities in the United States were regulated by the U.S.
Atomic Energy Commission (AEC), which also had federal responsibilities for the
development of nuclear power and radioisotope applications and for radioactive waste
management. With the Energy Reorganization Act of 1974, which abolished the AEC, the
responsibilities for regulation of commercial nuclear activities were vested in a new
organization, the USNRC. One of the provisions of the enabling legislation prohibited the
USNRC from establishing its own research and development laboratories and from
engaging in other than confirmatory research. The legislation encouraged the USNRC to
use DOE's laboratories and private sector organizations to perform the confirmatory
research necessary for the discharge of its regulatory responsibilities. A waiver was
granted in 1989 to the USNRC for the establishment of a federally funded research and
development center to provide an independent, long-term scientific and technological
capability to support the Agency's regulation and licensing of storage facilities for high-
level nuclear wastes from commercial nuclear power reactors.
Three characteristics taken hi combination distinguish the research programs within the
USNRC from the other two federal agencies described hi Section 9.1 and 9.2. First, all of
USNRC's research, except research conducted by the Center for Nuclear Waste
Regulatory Analysis, is performed under contracts, interagency agreements with other
federal agencies, and grants. Second, scope of the USNRC's research programs is
confined to confirmatory research, while the development of nuclear power reactors,
nuclear waste management options, and the application of nuclear materials, and design of
safety systems to protect the health and safety of the public, are reserved to others. Third,
the research projects sponsored by the Office of Nuclear Regulatory Research (RES) are
scoped and defined through negotiation of formal user needs raised by RES's customers
internal to the Agency, the Office of Nuclear Reactor Regulation (NRR), the Office of
Nuclear Materials Safety and Safeguards (NMSS), and the Office for Analysis and
Evaluation of Operational Data (AEOD). In addition, funding for the USNRC's research
program is derived from fees paid to the USNRC by its licensees. Because the research
program is user-needs-driven and fee-funded, it is responsive to its customers, and
transfer of the technology and use of the results occurs readily.
93.2 Mission
The USNRC nuclear regulatory research program has three main purposes. The first is
to provide independent expertise and information for making timely regulatory decisions.
The information should be independent in the sense that it is not derived solely from
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information provided by licensees and that it has received peer review by experts who did
not perform the research. Research required for this purpose is mostly oriented to
problems that are foreseeable in the near term. The second purpose is to anticipate
problems of potential safety significance for which new or expanded knowledge can assist
the USNRC in pursuing its missions. To this end, exploratory research is frequently
required to provide new knowledge. The expansion of knowledge can help to recognize
unforeseen situations and to prepare for dealing with them. Research for this purpose is
generally long term, requiring effort over a period of five to ten years. The third purpose
is to develop the regulations and regulatory guidance necessary to implement Commission
policy or technical requirements.
9.33 Organization and Operations
Currently the RES is divided into four divisions: Engineering, Safety Issue Resolution,
Systems Research, and Regulatory Applications. The director of this office reports to the
Executive Director for Operations who, in turn, reports to the USNRC.
The USNRC's research program is overseen by a federal staff of 125 scientists and
engineers who are professional project managers, that is, by individuals who possess both
technical and project management skills but are not currently hands-on researchers
themselves. Extensive peer review of project plans and research reports is performed
within contractor organizations, by the USNRC staff, and by external experts and advisory
committees (e.g., the Nuclear Safety Research Review Committee, the Advisory
Committee for Reactor Safeguards, and the Advisory Committee for Nuclear Waste). This
peer review complements the efforts by the project manager to ensure the quality of RES
products. The level of quality has generally been judged high by the advisory committees
and users of the information in the United States and abroad.
Several types of contracting vehicles are used by RES to obtain the capabilities it
requires from the categories of organizations shown in Table 9-6. Given its mandate to
use the DOE laboratories, it is not surprising to note that the majority of the research
funding is placed in those laboratories. Funding of universities is also important to the
USNRC to meet programmatic research needs while at the same time maintaining a
technical capability in universities to provide a source of USNRC employees in the future.
Contracts for work at DOE's national laboratories are consummated through a
streamlined version of commercial contracting procedures. Justification for the use of a
national laboratory must be prepared by the project manager prior to the release of a
statement of work (SOW) to the DOE operations office whose laboratory is deemed to
have the requisite facilities, staff, and experience. Proposals received from the laboratories
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Table 9-5. tLS. Nuclear Regulatory Commission Research Funding by Category
($ thousands, FY 1993)
DOE National Laboratories
University (includes educational contracts, and grants)
Private Contractor (includes commercial contracts,
SBIR, and not-for-profit contracts)
Foreign Agreements
Other (Government interagency agreements, and
not-for-profit grants)
Total USNRC Research Funding
$67,489
4,797
21,850
1,923
3,814
$99,873
Source: Office of Nuclear Regulatory Research, Financial Management,
Procurement, and Administrative Staff
are evaluated by the USNRC, and the approach, schedule, staffing, and costs are clarified
through discussions with the laboratory determined to be best suited for the project. A
standard contract including all terms and conditions is issued to the laboratory through the
DOE operations office.
Contracts and grants with universities and contracts with private contractors follow the
usual path of program announcements, sources sought announcements, and requests for
competitive proposals, followed by technical and cost evaluations by the USNRC. The
time required to complete these procedures is generally longer than the time needed to let
a contract with a DOE laboratory.
Quality assurance and quality control procedures under university and private
contractor agreements are similar to those followed in DOE contracts. Foreign government
contracts are negotiated on a case-by-case basis when the USNRC wishes to access
special research facilities that are not available in the United States.
9.4 SUMMARY
Two of the agencies discussed in this section, FDA and USNRC, share EPA's current
mission of environmental protection and the need to maintain long-range scientific and
technological competence while fulfilling the near-term needs of their regulatory
customers and of external regulated organizations. NIH shares with EPA a current and
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continuing common interest in the biological effects of environmental contaminants, and,
as EPA moves toward a scientific leadership role in the environment, NIH may provide
EPA insight into organizational and management practices that engender and foster a
strong science base. Obviously, EPA cannot and should not directly adopt or replicate the
practices of other federal agencies, but some insights can be obtained from these agencies
that should be considered when making changes in the EPA's laboratory structure and
management practices.
The FDA and USNRC address the need for credible science to support regulation
through two different mechanisms. FDA conducts a comprehensive intramural program
with limited extramural research, while the USNRC relies solely on extramural
contractors, particularly DOE's national laboratories. Both approaches can be made to
work, and EPA's management can determine what combination of the two is best suited
to its mission. The quality of the science and its use in the regulatory process is assured
in both organizations through extensive peer review process within and outside the
Agency. In addition, FDA has established a Senior Science Council composed of
scientists from each FDA center and the Office of Regulatory Affairs to advise the Senior
Advisor for Science on science issues throughout FDA. This approach supports the
assurance of end-to-end quality in the use of science.
Responsiveness of the research activities of the USNRC to its regulatory needs is
ensured through a formal user needs process. The adoption of a similar formal process is
something EPA may wish to consider as a part of the management improvements
described in Section 6.
All three agencies, but especially NIH, maintain and sustain a commitment to the
expansion of the scientific and technological information. USNRC fulfills this
commitment through its university programs and in part through its contracts with DOE
laboratories, and FDA and NIH use both their intramural and extramural programs to
expand the information base. The allocation of resources and the means to fulfill the
commitment rest with the agency management. A similar situation will exist within EPA.
In contrast to FDA and NIH, USNRC has not generally chosen to retain nationally
and internationally recognized scientists within its staff, but operates through professional
project managers. While such an approach seems to work well for USNRC and its
regulatory role, it may or may not be suitable for EPA.
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SECTION 10
ALTERNATIVE ACCOUNTABILITY MODELS
No study of laboratory options for EPA would be complete without an examination of
the prospects of fulfilling almost all of EPA's needs through the use of contractors. This
section discusses alternative accountability models that would free federal staff for
inherently governmental functions, while minimizing additional contractor oversight
responsibilities.
10.1 FEDERAL CONTRACT RESEARCH CENTERS
The term Federal Contract Research Center (FCRC) was first used in the early 1960s
by the.Department of Defense (DOD) to single out a particular sub-class of organizations
with which it was doing business. This designation was given to certain private, usually
non-profit, concerns that contributed directly to key planning, strategy, and management
policy functions of federal agencies. A typical list of areas of assistance provided by the
organizations includes the following:
• R&D program planning
• Research, experiment, and demonstration programs
• Systems design and engineering
• Implementation planning
• Preparation of specifications
• Integration of contractor design, testing, and implementation efforts
• Evaluation of contractor proposals
• Monitoring and evaluation of existing programs
• General technical support
• Consulting services
Each FCRC had a special relationship with one principal DOD sponsor. Later, other
agencies also developed special relationships with appropriate non-profit organizations
and, in the late 1960s, the term Federally Funded Research and Development Center
(FFRDC) was coined as a generic label for all such organizations regardless of the major
sponsor.
In 1972, the Commission on Government Procurement made the recommendation that
federal agencies shall "continue (to have) the option to organize and use FFRDCs to
satisfy needs that cannot be satisfied effectively by other organization resources." This
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recommendation led to Office of Federal Procurement Policy (OFPP) Policy Letter 84-1,
"Federally Funded Research and Development Centers" (Office of Management and
Budget, 4 April 1984). Among the criteria given for establishing an FFRDC relationship
was that it "is brought into existence...to meet some special research or development need
which, at the time, cannot be met as effectively by existing in-house or contractor
resources." The policy letter emphasized the long-term and special relationship that was
intended to exist between an FFRDC and its sponsor(s). Among the other characteristics
of this special relationship are the following (OFPP Policy Letter 84-1):
Work from other than a sponsoring agency is undertaken only to the extent
permitted by the sponsoring agency and accordance with the procedures of the
sponsoring agency.
The activity, whether the operator of its own or a government-owned facility, has
access, beyond that which is common to the normal contractual relationship, to
government and/or supplier data, employees, and facilities needed to discharge its
responsibilities efficiently and effectively, whether the data is sensitive/
proprietary.
• The primary sponsor undertakes the responsibility to ensure a reasonable
continuity in the level of support to the activity consistent with the agency's
need for the activity and the terms of the sponsoring agreement.
• The activity is required to conduct its business in a responsible manner befitting
its special relationship with the government, to operate in the public interest free
from organizational conflict of interest, and to disclose its affairs (as an FFRDC)
to the primary sponsor.
Policy Letter 84-1 sets forth an elaborate set of criteria for defining an FFRDC.
Basically, they are ad hoc R&D or study and analysis centers that are set up and/or
managed by industrial, academic, or other non-profit organizations, at the request of the
government, to help one or more federal agencies on a long-term basis to do that portion
of their job in some mission area that the government cannot get done as effectively in
any other way. The three main contributions an FFRDC brings to such an assignment are:
• A relatively unique knowledge and/or technical skill base in the mission area
• A willingness and breadth of capability for playing certain overview, "corporate
memory", and "honest broker" roles among and between the other organizational
participants in the various government programs in the mission area
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• As the major requirement, a willingness to tailor itself to operate on the
government's "side of the table" in the buyer/seller relationship that characterizes
government procurement, in such a way as to minimize any possible
organizational conflicts of interest that could arise from the special relationship
that the FFRDC has with both its sponsoring agencies and their suppliers.
In general, all of the following criteria must be met before an activity is identified as
an FFRDC (OFPP Policy Letter 84-1):
• The organization performs, analyzes, integrates, supports (non-financial), and/or
manages basic research, applied research, and/or development.
• Performance of the above functions is either at the direct request of the
government or under a broad charter from the government, but in either case the
results are directly monitored by the government. However, the monitoring shall
not be such as to create a personal services relationship, or to cause disruptions
that are detrimental to the productivity and/or quality of the FFRDC's work.
• The majority of the activity's financial support (70 percent of more) is received
from the government with a single agency usually predominating in that financial
support.
• Most or all of the facilities are owned by the government or funded, under
contract, by the government.
• The activity is operated, managed, and/or administered by either a university or
consortium of universities, other non-profit organization, or industrial firm as an
autonomous organization or as an identifiable separate operating unit of a parent
organization.
• A long-term relationship evidenced by specific agreement exists or is expected to
exist between the operator, manager, or administrator of the activity and its
primary sponsor.
Additional rules regarding the establishment, use, and termination of FFRDCs are set
forth in the Federal Acquisition Regulation (FAR) Part 35, Section 17.
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10.2 CONTRACTING AT GOVERNMENT-OWNED, CONTRACTOR-OPERATED
ORGANIZATIONS
In some cases, particularly when large properties are involved, the facilities are
actually owned by the federal government and only operated for it by an outside party. In
such cases, the facilities and its operation are also known as GOCOs. The use of private
contractors to manage and operate government facilities has enabled agencies such as the
Atomic Energy Commission and its successor agencies to attract the highly specialized
scientific and engineering talent from academia and the private sector that was not
otherwise available to the government. Not all GOCOs are FFRDCs, since not all of them
perform the activities given in the basic research, applied research, and/or development
discussed above.
This alliance between government and the private sector gave rise to the development
of the management and operating (M&O) contract, which can be the contracting vehicle
for either for-profit or not-for-profit contractor operations at government-owned facilities.
The FAR (Subpart 17.6) defines an M&O contract as:
an agreement under which the government contracts for the operation, maintenance, or
support, on its behalf, of a government-owned or controlled research, development,
special production, or testing establishment wholly or principally devoted to one or
more major programs of the contracting federal agency.
This type of contract contemplates long-term relationships under which the contractor
handles most aspects of day-to-day management, while the government pays virtually all
costs and exercises only broad, general oversight. Under M&O contracts, programs have
been carried out with a relatively small number of federal employees, who have served
mostly to provide general oversight, review, and programmatic direction. The M&O
contract is a cost-reimbursement contract under which the government reimburses all
reasonable ordinary business expenses of the contractor, subject to certain specified
exceptions and limitations. The contractor is also paid a fee (fixed or award) or
management allowance for performance of the work. In these respects, the M&O contract
is similar to the standard cost-type contract outlined in the FAR and used by other
government agencies. M&O contracts include very broad scopes of work, which are
intended to accommodate changes in such areas as available funds, national defense
needs, and the course of ongoing research. This approach permits work to continue
without the administrative burden of developing continual detailed revisions of the scope
of work.
With regard to funding and finance, the M&O contractors traditionally have functioned
in closer relationship to the government than most other cost-reimbursement government
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contractors. Most M&O contractor organizations are separate business entities from their
parent corporations, and the only work they perform is that work authorized under their
government contracts.
103 IMPLICATIONS FOR EPA LABORATORIES
In considering the use of alternative structures for the EPA laboratories, several
aspects of the structures, including formation and impacts on issues, are identified. Since
the criteria for an FFRDC require basic research, applied research, and/or development,
for the purposes of this discussion, the belief is asserted that neither the EPA program
office nor regional laboratories would have sufficient extensive activities in research and
development to justify the effort and disruption that would accompany a change from the
present status to FFRDC status. Further, since many of the activities undertaken by the
regional laboratories could be, and often are, performed by existing commercial
laboratories, who already have made the requisite capital investment, there would be no
incentive for the government to establish either a for-profit or not-for-profit GOCO
arrangement. Therefore, only the ORD laboratories will be discussed as possibilities for
FFRDC or GOCO status.
10 J.I Establishment of an FFRDC
With few exceptions, the 40 current FFRDCs were all organized out of already-
existing non-governmental groups to satisfy a government need that could not be
addressed, or could not be addressed as well, in some other way. To establish a new
FFRDC, an agency is required to meet a heavy burden of demonstrating that existing
private and federal facilities cannot meet its research needs. This burden was created to
discourage the creation of unneeded FFRDCs that take work away from the competitive
private sector or duplicate existing federal capabilities. An agency must also design a
mission statement that will allow it to differentiate between work to be performed by the
new FFRDC versus other research facilities, including those in the private sector. Under
FAR 35.017-2(c), the agency must also establish controls "to ensure that the costs of the
services being provided to the government are reasonable."
Once it demonstrates compelling need for a new FFRDC, an agency is required to
issue a contract, called a sponsoring agreement, to establish the FFRDC's research
mission, how the FFRDC will interact with the agency, and how the contractor will
operate the FFRDC to accomplish its mission. The contract term may not exceed five
years and usually extends for that period of time. It can be renewed after an agency
review for additional periods not to exceed five years.
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Most FFRDCs were established prior to the 1984 Competition in Contracting Act and
so were established without competitive procedures. In recent years, agencies have on
occasion used competition to determine who will operate a new FFRDC for the initial
five-year period. The Internal Revenue Service recently competed its FFRDC to support
tax system modernization. Universities, university consortiums, and corporations have all
been awarded contracts to operate FFRDCs.
10.3.2 Impacts on Issues
As discussed previously, the major issues identified at the laboratories have been
separated into four classes for this study—mission focus, expectations, locus of control,
and administrative impediments. The impacts of the alternative accountability models on
these issue areas is discussed here. The assumption is made that EPA would be the
sponsoring agency for an alternative structure. That structure will be referred to here as an
FFRDC, assuming a non-profit status.
10.3.2.1 Mission Focus
The concern with defining the mission of the laboratories would not be alleviated by
the imposition of either an FFRDC or GOCO structure. In fact, it might be worsened
since another layer of management—that of a university or corporation—would be
introduced. EPA would still have to provide direction on long-term versus short-term
research.
103.2.2 Expectations
The introduction of an alternative structure would not solve the problems associated
with the difference in expectations, although it might alleviate at least one of them.
Role of staff: Because new staff would be hired by the FFRDC, they would
better understand their role as scientist or contract manager, so that the
expectations of the present employees at the laboratories would be brought into
alignment with the needs of the organization.
• Excellence in science: The expectation for excellence in science would not
necessarily change, since the FFRDC would need to employ top scientists to
maintain its contract. The expectation of an ability to respond to emergency
needs would not change.
Emergency needs: The clients of the present laboratories expect that the
laboratories will be available to respond to emergency needs with directed
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research. At the present time, these emergencies displace the ongoing research at
a laboratory, since time, not money, is the currency for meeting the need. An
FFRDC could set aside a portion of its funds to meet emergency needs of its
sponsor and could hire additional personnel, either permanent or temporary, to
accommodate the need.
103.2.3 Locus of Control
Although EPA would still have to provide direction on focus of research and
prioritization of issues, control over resources, both personnel and money, would devolve
to the level of the alternative structure.
• Personnel: An FFRDC could make decisions on number and type of personnel
hired without the strictures, or protections, of the federal personnel system. If an
FFRDC were introduced at a laboratory, the probability is that most, but not all,
of the present staff would be hired as employees of that FFRDC. Flexibility
would be added to the system but without the guarantees of the present federal
system. If a laboratory had what the managing organization considered an
overabundance of a particular type of scientist, not all of these persons would be
retained.
• Budget: An FFRDC would give the local organization more control over the
spending of resources. One of the issues raised at the laboratories was the lack of
travel money as opposed to the abundance of equipment money. An FFRDC
could contract on how to spend the money it receives from its sponsor. The
timeliness of acquisitions would be improved since the FFRDC would know its
budget farther in advance.
10.3.2.4 Administrative Impediments
Many administrative issues were discussed at the laboratories. The impacts of an
FFRDC on some of these are discussed below.
• Interactions with contractors: With the reduction of contractors at the EPA
laboratories, the past interactions that took place collegially among researchers
and support staff no longer occur. If the researchers and support staff were both
employees of the alternative organization, these collaborations would be possible
once again.
• Perceived micromanagement: Although the use of an FFRDC would add a
layer of management, at the same time it would reduce interactions with ORD
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headquarters personnel. Decisions would be made at the local, rather than
headquarters, level.
Streamlining! One of the points of discussion in the streamlining effort has been
the reduction in the number of ORD federal employees in the higher grades
(14 and above). The use of an FFRDC would aid in this effort by converting
some of these positions at one or more laboratories from federal employees to
FFRDC employees.
10.4 CONCLUSIONS
One of the major concerns with the initiation of the type of alternative accountability
model discussed above is that EPA has no experience in dealing with such a structure.
The time required to set up the structure, and the decisions that would go into the
implementation would be very consumptive of resources, including personnel time for
planning. The costs and benefits, whether the solicitation would be competed, and
negotiating an M&O contract are only a few of the many issues that would require
investigation.
Many of the issues that have been identified can be solved with less disruptive
measures, as discussed in Section 6.
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SECTION 11
FINDINGS
In the course of meeting the study objectives to develop a baseline description of all
of EPA's laboratories and to assess options for physical, functional, and organizational
consolidation, a number of findings were made. The purpose of this section is to
summarize the major findings presented throughout this report. These findings are
intended for consideration by those who will be developing EPA's recommendations for
potential consolidation of EPA laboratories and for potential Agency changes intended to
improve the efficiency, effectiveness, and quality of EPA's laboratory operations.
In the FY92 annual report of the SAB, it was concluded that "insufficient funds and
FTEs pose a serious threat to the continued viability of the EPA research program." The
SAB went on to raise its major concerns, including (1) excessive reliance of on-site
contracts for research, (2) attrition of federal career scientists, and (3) increasing
obsolescence of equipment and facilities. The current EPA laboratory study found all of
these observations still relevant. Additional findings are summarized in the following
pages.
MISSION
To achieve improvements in the quality, efficiency, and effectiveness of the laboratory
system, it is essential to develop an agreed-upon statement of the mission of the Agency
and to implement a top-down strategy for laboratory operations in support of it. The
Agency's mission with regard to scientific and technological activities also needs updating
and refining in light of the increased involvement over the past 20 years in environmental
issues by other federal agencies. The Agency's laboratories could, in turn, revise their
missions, sharpening the focus and eliminating the potential for redundancies. During the
past 10 to 15 years, as research budgets have decreased, it appears that some laboratories
interpreted their missions more broadly in an effort to maintain or expand the size of their
operation. The Agency's mission rather than funding opportunities should be used to set
the agenda for the scientific and technological activities.
FINANCE
In FY93, EPA's laboratory system (including the regional QA and field monitoring
functions) spent a little over $500 million. (Superfund CLP extramural funds have not
been included in this figure). This was 12 percent of the Agency's operating budget
(appropriations less revolving funds), which seems low for an agency that depends upon
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credible science to support development and enforcement of environmental regulations.
For the 20 ORD laboratories, a total of $392.5 million was expended in FY93 with only
35 percent being intramural funds. This suggests that much of EPA's science base lies
outside the Agency. The contractor conversion steps that are planned will increase the
portion of funds being spent intramurally. For the program office laboratories and ESOs,
74 percent of the total expenditures is for intramural activities.
Agency-wide financial analyses are constrained by the categories of funds reported in
the Agency's financial systems and the level of organizational units reporting data. For
this study, core functions were used to define the ESOs, but data are not reported to the
financial system by these functions, so separate calculations had to be performed.
Financial analysis of consolidation options could not be performed without supplementing
the information currently in the Agency's financial system. In addition, ORD's research
plans are being developed around issues, but the financial performance cannot be tracked
within the laboratory.
FACILITIES
Of the 20 ORD laboratories, only two, LLRS and RGB, have been rated by EPA's
FMSD as in poor condition, and both are EPA-owned. Three of the program office
laboratories are classified as in poor condition: NEIC and both pesticide laboratories
(ACL and ECL). The facilities in Region 2, 3, 5, and 8 are classified as poor, and the
Agency is far along in its plans to build a new laboratory for Region 3. Many of the
laboratory facilities are in need of significant repairs requiring substantial financial
resources. Information compiled in this report on the facilities includes and supplements
the headquarters information and should be useful input to the Agency deliberations
regarding consolidation.
The FMSD staff need to be kept informed of laboratory consolidation being
considered by the Agency so that they do not make commitments for new leases or
budget funds for plans or new construction projects not consistent with Agency
recommendations being developed out of this study. Long lead times are required to
construct new facilities, renovate existing facilities, or lease different facilities. The EPA
staff working on such projects have the best access to the necessary data and
understanding of that data to prepare estimates of implementation costs and times
associated with laboratory reconfigurations.
EQUIPMENT
For ORD laboratories, total equipment investments of at least $2 million to $3 million
per year are needed in the $50,000 and above budget category to maintain their current
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capabilities; enhancements to their capabilities would require additional funding. For the
limited number of program office laboratories that reported data, the total is in the
$500,000 to $700,000 range. For the ESOs, total investments of $800,000 to $1,000,000
are required. Any option involving physical consolidation should result in a reduction in
these costs. Data on equipment expenditures and inventory came from several sources and
did not always agree with what individual laboratories possessed. Consideration should be
given to improving the current reporting systems and equipment databases, to allow
Agency-wide review of equipment requirements, expenditures, and current inventory.
HUMAN RESOURCES
The Workforce '94 study has made a large quantity of data available to this study. The
data on disciplines, age, and activity have been reviewed. These data have been used to
help characterize the current laboratory operation and support the option evaluation.
In the interviews at several laboratories, concern was expressed about the large number
of staff nearing retirement. Age information obtained from the EPA Payroll System
(EPAYS) shows that the percentage of staff in each grade category is greatest in the 46-
to 50-year-old age category. Retirement profiles for individual laboratories were obtained
from the Workforce '94 database and document the concerns expressed. These data are
included as part of the baseline description and, while not used directly in the option
evaluation, can be used to project hiring needs.
No single EPA database exists that could provide information on the human resource
characteristics discussed above. Workforce '94 was conducted to provide the required
information, but it only covered part of the Agency. If policy makers feel this type of data
would be valuable for other agency studies, consideration should be given to conducting a
similar work force study Agency-wide. A database containing human resource data for the
entire Agency could be updated annually and used for all Agency studies of management,
facilities, career development, and training needs.
QUALITY ASSURANCE
To improve QA in the performance and use of science and technology throughout
EPA, an in-depth review of the existing process should be made, particularly with the
objective of achieving end-to-end QA throughout all of EPA's activities. The formal
QA/QC responsibilities are not given the highest organizational visibility in EPA. The
question of whether the QA functions should report to the Administrator/Deputy
Administrator should be addressed. Consideration should also be given to having the
group performing the laboratory QA function report to the directors of ESOs rather than
to the laboratory management. Regions 1, 6, 8, 9, and 10 are presently organized this way.
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ISSUE-BASED PLANNING
During interviews with ORD customers, ORD office directors, ORD laboratory
directors, and other personnel, concern was expressed that there were too many issues for
them to cover in the planning process. Several issues have been combined reducing to 36
the total number currently being used for planning. However, of these 36, RREL, for
example, has funding and/or FTEs from 15 of them. While it may be necessary to
partition the issues among the ORD laboratories to encompass the full range of expertise
needed, it places management burdens on the ORD laboratory director to control the
resources appropriately and upon the issue planner to integrate the results. Further
examination of the situation could indicate how ORD laboratories might be consolidated
or how the issues could be better defined.
INFORMATION SYSTEMS
As mentioned in some of the other findings above, Agency-wide information systems
in the areas of finance, human resource, facilities, and equipment could enhance the
Agency's ability to perform studies such as this. Systems that could be easily accessed
that use common data formats and are updated at least monthly would help the Agency
work more efficiently and effectively when searching for these types of information.
MANAGEMENT IMPROVEMENTS
Improvements in quality, efficiency, and effectiveness can be gained through improved
management policies and procedures regardless of the organizational structure that is
adopted. In addition to QA and mission clarification discussed above, five areas are
identified for potential management improvement at all three types of laboratories:
• Establish QA as a visible high-level function
• Perfect the issue-based planning process
• Create a customer orientation throughout the Agency with a clearly focused and
articulated mission statement
• Improve the information management system to increase the accessibility of
managers to complete, consistent, and accurate data
Delegate authority to the lowest level of management consistent with federal
policies
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LABORATORY SYSTEM RECONFIGURATION
In this report, five options were defined and evaluated. All of the options were
evaluated twice, once with the physical consolidation or relocation of the resources and
once without.
If the options are implemented without physical consolidation, the implementation time
is short, since the changes from the current operations are mainly those of reporting
relationships. Implementation costs would be expected to be substantial for physical
consolidation of the laboratories, but no quantitative estimates of these costs have been
made as yet by EPA or MITRE. Since the Carnegie Commission option affects only the
ORD laboratories, and the DESO option affects only the ESOs, these options should not
be compared.
Among the positive aspects of the options, the Carnegie Commission option with
physical consolidation was evaluated more favorably than any of the other options that
involve ORD. In the areas in which the Carnegie Commission with consolidation was
strongly positive—human resources, mission focus, locus of control, functional alignment,
and concentration of resources—none of the other options that would affect the ORD
laboratories was as positive.
The strongly positive aspects of the Geographical Location option, i.e., its multimedia
approach resulting from place-based ecosystem orientation, could be implemented under
other options as well. This is true also of the strongly positive aspects of the Customer
Orientation option—customer satisfaction and focusing on the highest priorities of the
Agency.
The Streamlining option was neutral for most of the criteria, although it could reduce
operating costs. If the provisions of this option were implemented under either the
Carnegie Commission or DESO option, similar savings could be achieved.
The evaluation of the DESO option illustrated that it could have positive effects on the
stature of the laboratories and the mission focus, although it is strongly negative with a
large loss in customer satisfaction, an area in which the ESOs are now highly regarded.
With consolidation, some savings would be seen in operating, facilities, and equipment
costs, but other benefits are offset by the decline in customer satisfaction. The Geographic
Location option would provide improvements in the area of customer satisfaction, where
the DESO option was very weak.
The option judged to be most negative, Geographic Location with consolidation, would
affect all three types of laboratories. This option was evaluated as strongly negative for
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functional alignment—a criterion for which the Carnegie Commission option with
consolidation was judged strongly positive. In the Carnegie Commission option,
consolidation reinforced the functional alignment, while the Geographic Location option
did not. The alignment resulting from the Geographic Location option was perceived as
expensive and not productive; it was seen as having the negative aspects of
relocation—disruption and high costs—and few of the advantages of the Carnegie
Commission option.
The assessments made by MITRE of the restructuring options have been useful in
identifying the major controlling factors that must be addressed by EPA in making its
report to Congress. However, there are also opportunities for EPA to improve the
efficiency and effectiveness of its operations through management changes. The following
changes appear reasonable to MITRE for eliminating the apparent duplications of facilities
and equipment and for increasing the disciplinary strengths of the human resource base:
• Consolidate laboratories in the Office of Prevention, Pesticides, and Toxic
Substances and the two laboratories under the Office of Radiation and Indoor Air
Realign and consolidate the ORD laboratories in the manner of the Carnegie
Commission option
• Reduce the number of laboratories within the Regional Offices through
consolidation to a few laboratories with national service focus.
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SECTION 12
BIBLIOGRAPHY
Benferado, Jay, Deputy Director Office of Science, Planning and Regulatory Evaluation,
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Brown, George E., and Radford Byerly, Jr., 27 March 1981, Research in EPA: A
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Carnegie Commission, December 1992, Environmental Research and Development:
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Finch, Carol, Chairman, Lab Consolidation Committee, July 1982, Progress Report,
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Office of Administration and Resources Management, EPA, December 1993, Creating A
U.S. Environmental Protection Agency That Works Better and Costs Less: Phase II
Report, National Performance Review, EPA/210-R-93-005, Washington, DC: EPA.
Office of Management and Budget, Office of Federal Procurement Policy, 4 April 1984,
Federally Funded Research and Development Centers, OFPP Policy Letter 84-1,
Washington, DC.
Office of Policy Analysis, EPA, February 1987, Unfinished Business: A Comparative
Assessment of Environmental Problems, Overview Report, EPA/230/2-87/025a,
Washington, DC: EPA.
Office of Research and Development, EPA, July 1991, Work Force '91, Appendix,
Washington, DC: EPA.
Office of Research and Development, EPA, January 1993, EPA Organization for
Environmental Research: The Third Decade, EPA/600/R-92/246, Washington, DC: EPA.
Office of Research and Development, EPA, February 1993, Report to Congress:
Fundamental and Applied Research at the Environmental Protection Agency, EPA/600/R-
93/038, Washington, DC: EPA.
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Office of Research and Development, EPA, August 1991, Work Force '91, EPA/600/9-91-
029, Washington, DC: EPA.
Office of Research and Development, EPA, July 1993, Technical Assistance Directory,
EPA/600/K-93/006, Cincinnati, Ohio: EPA.
ORD Laboratory Directors' Group, Office of Research and Development, March 1994,
Position Paper on ORD Streamlining (Draft).
Perciasepe, Robert; David Gardiner; and Jonathan Cannon; 16 March 1994, Toward a
Place-driven Approach: The Edgewater Consensus on an EPA Strategy for Ecosystem
Protection (Draft), Memo and document, EPA, Washington, DC.
Preuss, Peter W., et al., February 1994, Redesigning Research at EPA: Proposed Changes
to Mission, Organizational Structure, and Streamlining in the Office of Research and
Development, Memo.
Rhoades, Russell, Director, Environmental Services Division, EPA Region 6, 2 February
1994, EPA Laboratory Study, Memo.
Risk Reduction Engineering Laboratory and Environmental Monitoring Systems
Laboratory, May 1992, Underground Storage Tank Research Program.
Science Advisory Board, March 1991, The Science Advisory Board: Working Smarter,
Annual Report of the Staff Director of the Science Advisory Board for Fiscal Year 1990.
Washington, DC: EPA.
Science Advisory Board, Health Effects Research Review Group, February 1979, Report
of the Health Effects Review Group, Washington, DC: EPA.
Science Advisory Board, Relative Risk Reduction Strategies Committee, September 1990,
Reducing Risk: Setting Priorities and Strategies for Environmental Protection, SAB-EC-
90-021, Washington, DC: EPA.
Science Advisory Board, Research Strategies Advisory Committee, 28 July 1992, An SAB
Report: Review of 14 Strategic ORD Research Issues for FY 1994,
EPA-SAB-RSAC-92-022.
Sexton, Ken, and Lawrence W. Reiter, 1989, Health Research at the U.S. Environmental
Protection Agency, Environmental Science and Technology 23(8):917-924.
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Shifrin, Robin, November 1992, Not by Risk Alone: Reforming EPA Research, Yale Law
Journal 102(2): 547-575.
Sussman, Robert, 19 April 1994, Statement Before the Subcommittee on Technology,
Environment, and Aviation; Committee on Science, Space, and Technology; U.S. House of
Representatives.
U.S. Congress, Committee on Science, Space, and Technology, U.S. House of
Representatives, 1991, Report on Environmental Research, Development, and
Demonstration Activities at the Environmental Protection Agency, December 1990,
Washington, DC: U.S. Government Printing Office.
U.S. Congress, Committee on Science, Space, and Technology, U.S. House of
Representatives, 4 May 1993, Fiscal Year 1994 Authorization: The EPA Office of
Research and Development, Hearing Before the Subcommittee on Technology,
Environment, and Aviation of the Committee on Science, Space, and Technology, No. 20,
Washington, DC: U.S. Government Printing Office.
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570, Washington, DC: U.S. Government Printing Office.
U.S. Environmental Protection Agency, 23 March 1994, Setting National Goals for
Environmental Protection, Draft, Washington, DC.
U.S. General Accounting Office, June 1993, Hospital Sterilants Insufficient FDA
Regulation May Pose a Public Health Risk, GAO/HRD-93-79, Washington, DC: General
Accounting Office.
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GLOSSARY OF ACRONYMS
AA Assistant administrator
AC&C Abatement, control, and compliance
ACL Analytical Chemistry Laboratory
AEC Atomic Energy Commission
AEERL Air and Energy Engineering Research Laboratory
AEOD Office of Analysis and Evaluation of Operational Data
AREAL Atmospheric Research and Exposure Assessment Laboratory
B&F Buildings and facilities
CBER Center for Biologies Evaluation and Research
CDC Center for Disease Control and Prevention
CDER Center for Drug Evaluation and Research
CDRH Center for Devices and Radiological Health
CERCLA Comprehensive Environmental Response, Compensation and Liabilities Act
CFSAN Center for Food Safety and Applied Nutrition
CVM Center for Veterinary Medicine
DESO Distinct Environmental Services Organizations
DOD Department of Defense
DOE Department of Energy
EAC Environmental Assessment Center
EAG Exposure Assessment Group
ECAO Environmental Criteria and Assessment Office
ECAP Environmental Criteria Assessment Program
ECL Environmental Chemistry Laboratory
EMA Environmental Monitoring Agency
EMAP Environmental Monitoring and Assessment Program
EMB Emission Measurement Branch
EMSL Environmental Monitoring Systems Laboratory
EPA U.S. Environmental Protection Agency
EPAYS Environmental Protection Agency Payroll System
EPIC Environmental Photographic Interpretation Center
ERI Environmental Research Institutes
ERL Environmental Research Laboratory
ESAT Environmental Sampling and Analysis Team
ESO Environmental services organization
F&E Facilities and equipment
FAR Federal Accounting Regulation
FCRC Federal Contract Research Center
FDA U.S. Food and Drug Administration
FFRDC Federally Funded Research and Development Center
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FIFRA Federal Insecticide, Fungicide, and Rodenticide Act
FMSD Facilities Management and Services Division
FTE Full-time equivalent
FY Fiscal Year
GAO General Accounting Office
GE General Electric Company
GOCO Government-owned, contractor-operated
GSA General Services Administration
HERL Health Effects Research Laboratory
HHAG Human Health Assessment Group
HHS Department of Health and Human Services
ICP-MS Inductively Coupled Plasma-Mass Spectrometer
IEA Institute for Environmental Assessment
LLRS Large Lakes Research Station
LUST Leaking underground storage tank trust fund
M&O Management and operating
NAPA National Academy of Public Administration
NAREL National Air and Radiation Environmental Laboratory
NASA National Aeronautics and Space Administration
NCTR National Center for Toxicological Research
NEC National Environmental Council
NEEL National Environmental Engineering Laboratory
NEIC National Enforcement and Investigation Center
NEML National Environmental Monitoring Systems Laboratory
NEP National Environmental Plan
NESL National Ecological Systems Laboratory
NHEL National Health Effects Laboratory
NIE National Institute of Environment
NIER National Institute of Environmental Research
NIH National Institutes of Health
NMSS Office of Nuclear Materials Safety and Safeguards
NOAA National Oceanic and Atmospheric Administration
NRC National Research Council
NRR Office of Nuclear Reactor Regulation
NSF National Science Foundation
NVFEL National Vehicle and Fuel Emissions Laboratory
OAQPS Office of Air Quality Planning and Standards
OARM Office of Administration and Resource Management
OEETD Office of Environmental Engineering and Technical Demonstration
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OEPER Office of Environmental Processes and Effects Research
OER Office of Exploratory Research
OFPP Office of Federal Procurement Policy
OGWDW Office of Ground Water and Drinking Water
OHEA Office of Health and Environmental Assessment
OHR Office of Health Research
OMMSQA Office of Modeling, Monitoring Systems, and Quality Assurance
ORD Office of Research and Development
ORIA Office of Radiation and Indoor Air
ORPM Office of Research Program Management
OSHRC Occupational Safety and Health Review Committee
OSPRE Office of Science, Planning and Regulatory Evaluation
PAMS Photochemical Assessment Monitoring Systems
PEB Pacific Ecosystems Branch
PHS Public Health Service
PMS Program Management System
PPAYS Personal Property Accountability System
PRO Program and resource operations
QA/QC Quality assurance/quality control
R&D Research and development
R&I Repair and improvement
RGB Releases Control Branch
RCRA Resource Conservation and Recovery Act
RES Office of Nuclear Regulatory Research
RREL Risk Reduction Engineering Laboratory
RSKERL Robert S. Kerr Environmental Research Laboratory
RTP Research Triangle Park, North Carolina
SAB Science Advisory Board
SERDP Strategic Environmental Research and Development Plan
SES Senior Executive Series
SF Superfund
SOW Statement of work
TRI Toxic Release Inventory
TSCA Toxic Substances Control Act
USGS U.S. Geological Survey
USNRC U.S. Nuclear Regulatory Commission
WRC Westhollow Research Center
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APPENDIX A
LABORATORY DESCRIPTIONS
The large quantity of laboratory descriptions made it necesary to compile these
descriptions in a separate volume of this document, MTR-94W-0000082V2.
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APPENDIX B
SCHEDULE HIGHLIGHTS
17 November 1993
13 December 1993
30 December 1993
11 January 1994
5-21 January 1994
3 February 1994
11 February 1994
4 April 1994
18 April 1994
4 May 1994
12 May 1994
31 May 1994
23 June 1994
Jan-May 1994
MITRE Effort Initiated
Senior Executive Interviews Initiated
Delivery of Draft Study Plan
First Meeting with National Academy of Public
Administration (NAPA)
Participated in Briefings to EPA Laboratory Personnel
Initiated Laboratory Visits and Interviews
Delivery of Final Study Plan
Second Meeting with NAPA
Draft Report Submitted for Agency Review
Addenda to Draft Report Submitted to Agency
Study Review by Research Strategies Advisory Committee,
Science Advisory Board
Delivery of Final Report
MITRE testifies before the House Committee on Science,
Space and Technology, Subcommittee on Technology,
Environment and Aviation
Attended twice-monthly EPA Steering Committee Meetings
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APPENDIX C
EXECUTIVE INTERVIEW SUMMARIES
This appendix includes the following executive interview summaries:
INTERVIEW PAGE
Herb Barrack, Regional Administrator, Region 2 C-3
Michael Cook, Director, Office of Wastewater Enforcement and C-10
Compliance, Office of Water
Peter Cook, Deputy Director, Office of Ground Water C-12
and Drinking Water
Tudor Davies, Deputy Assistant Administrator of Water (Acting) C-13
Scott Fulton, Deputy Assistant Administrator of Enforcement C-15
Lynn Goldman, Assistant Administrator, Office of Prevention, C-16
Pesticides, and Toxic Substances
Ann Goode, Acting Assistant Administrator for Air and Radiation C-18
William Hunt, Branch Chief, Monitoring and Reports, Technical C-19
Support Division, Office of Air Quality Planning and Standards
Floyd Kefford, Director, Bureau of Laboratories, Pennsylvania C-20
Department of Environmental Resources
Walter Kovalick, Acting Deputy Assistant Administrator, C-23
Office of Solid Waste and Emergency Response
Jerry Kurtzweg, Director, Office of Program Management Operations C-25
Office of Air and Radiation
Stan Laskowski, Acting Regional Administrator, Region 3 C-26
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INTERVIEW PAGE
Susan Lepow, Associate General Counsel of Water C-28
Henry Longest, Director, Office of Emergency and Remedial Response C-29
(Superfund), Office of Solid Waste and Emergency Response
Jack McGraw, Acting Regional Administrator, Region 8 C-30
Richard Morgenstern, Assistant Administrator for Policy, C-31
Planning, and Evaluation
Jean Nelson, General Counsel C-33
Margo Oge, Director, Office of Radiation and Indoor Air, C-34
Office of Air and Radiation
Robert Perciasepe, Assistant Administrator for Water C-36
William Rice, Acting Regional Administrator, Region 7 C-37
John Seitz, Director, Office of Air Quality Planning and Standards C-39
Office of Air and Radiation
Michael Shapiro, Office of Solid Waste C-41
Robert Wayland, Director, Office of Wetlands, Oceans and Watersheds C-43
Richard Wilson, Director, Office of Mobile Sources, Office of C-45
Air and Radiation
John Wise, Deputy Regional Administrator, Region 9 C-46
Gerald Yamada, Principal Deputy General Counsel C-48
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Scientific and Technical Laboratories and Facilities
Interview Summary
Date of Interview: 22 December 1993
Person Interviewed: Herb Barrack, Regional Administrator, Region 2
Response submitted in writing as follows:
Scientific and Technical Issues
Science and Technology data, information—quality, response time, reliability.
The regional laboratories support the following:
• Collection of samples and generation of analytical data for project specific media programs
(air, water, and hazardous waste) to support compliance, monitoring, and enforcement activities
in the region
• Development of quality assurance project plans to support enforcement actions, remediation
goals, and decision making
• Evaluation of whether ambient standards are in compliance with Agency regulations
• Geographic-specific initiatives
To support these activities, it is essential that the region have the highest quality data. Assessment
of data quality objectives is an essential first step in the process to ensure that proper procedures are
used in the collection of data, that the methods meet the data quality objectives, and that the
information can be used in decision making. For example, among the different programs, there are
different methods for sampling lead in water. Under RCRA, sampling procedures are at the 5 ppm
range, while under the Safe Drinking Water Act requirements are for 15 ppb. These sampling
procedures have significantly different costs, and it is essential that in selecting sampling
methodologies that program-specific needs are met.
The laboratories also play a significant role in the region's ability to quickly respond to
environmental episodes and catastrophes. For example, in Region 2, the laboratory was essential to
identifying chemical contaminants when the Chemical Control Company of Union County in
Elizabeth, New Jersey exploded in 1980. Considering current public concerns about potential chemical
exposures, it is essential that the Regional Administrator have access to the expertise to analyze and
address environmental crises in a timely manner.
The laboratory staff also provide a technical base of knowledge in analytical techniques that is
invaluable in supporting Agency enforcement cases. This technical knowledge provides a firm
foundation for the regional scientists to serve as expert witnesses in winning enforcement cases.
Without the continuation of the laboratory there is a potential that this knowledge base might be lost.
In the regions, the response time varies depending upon regulatory requirements. Similarly, to
support regulatory decisions and response from industry, it is essential that the region establish
credibility and reliability in the development of the data. Response time is also dependent on the
urgency of the situation; if danger to the public is imminent, response time must be immediate; this is
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one of the unique capabilities of the regional labs (quick turnaround time for data generation so that a
decision can be made).
Technical Assistance and Support. All programs within the regions are required to submit project
specific quality assurance project plans before any sampling or data analysis is started. The technical
analysis of the project plan ensures that the data objectives are clearly identified, that sampling
procedures are appropriate to meet these objectives and that the results meet these objectives.
The Environmental Service Division provides training in the development of quality assurance
procedures, formal review of Quality Assurance Project Plans developed by our states and local
agencies where appropriate, and telephone discussions where appropriate. Our regional laboratory
expertise is currently being transferred to laboratories in Eastern Europe.
The regional laboratories also coordinate with the research and development laboratories in Las
Vegas and Cincinnati to identify appropriate methods to meet regional needs and to share field
experience in the application of these methods.
It is important to keep in mind that the regional laboratories and the research and development
laboratories have different missions. For example, the regional laboratories must respond to emergency
situations or site-specific problems within strict deadlines. The research and development laboratories
have greater flexibility in the method development and validation process. It is important in developing
new structures for ORD that the team keep in mind the distinctions in the missions of these different
parts of ORD.
Risk Assessment The region uses risk assessment as a tool for evaluating potential exposure to
chemical mixtures at Superrund sites, RCRA facilities, and ambient air toxicants. Comparative risk
analysis is used as a tool to comparatively rank various environmental problem areas and support
strategic planning.
Scientific or technical assessment or evaluation. As indicated previously, in many site-specific
analyses as a final step we rarely evaluate the data from the project in relation to the original data
quality objectives. In many cases, depending on the length of the project, the number of scientists
involved, and the changes in personnel there is a potential to lose sight of the original objectives. It is
important that we develop better plans to carry out the final step of reviewing the collected
information versus the original data objectives to ensure that we have met the objectives. If the
objectives are not met, it is important that we identify ways to improve the process for the future.
To support regional and geographic specific decisions, it is important to develop appropriate
models for fate and transport analysis of contaminants in a temporal manner, develop computerized
systems to store data that can be easily used by non-computer specialists, and develop procedures for
validating models and indicating appropriate conditions for the use of the model. As indicated in the
recent meetings on the workplan for the Waste Technology Industries (WTI) incinerator in Ohio, the
Agency selected model was not appropriate for the complex terrain conditions in the area of the
incinerator. It is essential that better scientific and technical analyses be developed to support the
selection of the appropriate model and that a formal Method for approving models be developed.
In the area of risk assessment we have utilized ORD offices, expertise in developing modeling,
exposure assessment, and toxicology to review media-specific workplans and risk assessments. It is
essential that these resources be made available to help support regional and site-specific actions.
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Quality Assurance. Coordination between the research laboratories that develop the methods, the
Headquarters Quality Assurance office, and the regions to use validated methods must continue to
support regional decision making. It is essential that a centralized data repository of regulated methods
and their validation be developed so that quality assurance is integrated across all program offices and
consistency is developed. In the future, we need to use current computer technologies to ensure that
this information is available for use across all program offices to ensure against duplication of effort.
Peer reviews of programs or activities. We have utilized ORD's expertise to peer-review media-
specific workplans and risk assessments; currently Region 2 is developing its own peer-review policy.
Science and technology review of proposed regulations. One area where this overlap in
responsibilities presents special problems is the area of standard development. For example, many
regulations are developed based on health, ecological or economic considerations. In some cases, such
as dioxin, the regulatory limits set for specific criteria cannot be measured using current sampling
methodologies and therefore it is difficult to determine whether the facility is in compliance with the
permit levels. It is essential that questions of sampling methodology be addressed earlier in the
regulatory process so that the regulators can make appropriate decisions before the method is
promulgated.
Success in Addressing Identified Needs
Coordination within the Agency's program specific laboratories, research laboratories, and regional
laboratories is essential to ensuring that the methods are available to support geographic and site-
specific regional needs.
In the regional laboratories we use the management tool of workplan development to ensure that
we do not over-commit our resources and continue to provide quality scientific data. It is essential that
special consideration be given to providing additional resources to the regional laboratories to provide
the flexibility to address regional specific problems. Of special concern are those geographic specific
problems that cannot be anticipated. Additional resources can help to provide a cushion of expertise to
address these geographic needs on an as-needed basis. For the region, it is essential that we develop
better facilities to carry out laboratory research. The laboratory should provide state-of-the-art design
to reflect the various types of analyses that are carried out.
In the area of risk assessment, the regions are faced with a lack of Agency consensus information
on specific chemicals. Alternatively, we need to identify other potential sources of risk specific
lexicological information (i.e., other program offices, states and other sources). It is essential that the
regions have the opportunity to identify specific needs for fast-track review by existing workgroups
(i.e., CRAVE, RfD/RfC) so that these needs are addressed in a timely manner. In addition, if
consensus numbers are removed, it is essential that the regions have access to the original numbers
since our experience has shown that revised numbers are not readily forthcoming.
Changes in Function and Structure
It is important for the Agency to reaffirm its commitment to use the best science available and
support the Agency scientists in this endeavor. It is important that the Agency become more active in
addressing science issues in a timely manner. Strategic planning is essential in the process.
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For the regional laboratory, it is essential that we develop better facilities to carry out laboratory
functions. Our current laboratory facilities are old and require significant updating to meet the
changing scientific developments.
It is also essential that we fully consider the importance of the QA/QCed data provided by the
laboratories and ensure that adequate staff are available to meet existing and future needs.
Coordination among the various program offices, laboratories, and regions is essential in
identifying critical areas where additional research is required, assuring against duplication of efforts
and assuring the best science is used in decisions. It is also important that we coordinate with other
federal agencies on specific issues to avoid duplication of effort.
Where possible, it is essential to provide travel funds to support regional participation on national
workgroups to discuss specific methods and applications to ensure that field experience and expertise
is appropriately incorporated into development of new methods.
Future Scientific and Technical Needs
Fundamental research (Environmental Monitoring and Assessment Program [EMAP] and
National Human Exposure Assessment Survey [NHEXAS]). Under the NHEXAS program it is
essential that the data from the project be made available in a timely manner so that it can be used to
develop better risk methodologies for evaluating sensitive subpopulations and addressing
environmental justice issues. The NHEXAS data could also be potentially used to evaluate progress in
reducing the levels of various toxic pollutants in the environment (i.e., DDT, dioxin, lead, and PCBs).
As part of fundamental research, it is important that we develop mechanisms (funds, resources,
etc.) for the regions to address smaller, geographic-specific problems that are not amenable to the
larger E-MAP and NHEXAS projects. In many cases, the time that it will take to complete the larger
projects does not meet the regions more immediate needs, and flexibility is required to address these
issues.
Risk Assessment Methods. Risk assessment methods are needed for both human health and the
ecological analyses. For human health in the following methods are needed:
• Assessing potential health effects from non-carcinogens
• Evaluating both cancer and non-cancer health effects
Addressing physical habitat alteration
Addressing fate and transport of chemicals, biomagnification especially related to the current
combustion strategy under RCRA
• Sampling methods able to detect contaminants at the carcinogenic and non-carcinogenic risk
levels
• Statistical methodologies to quantitatively evaluate risks (Monte Carlo, Meta analysis, etc.)
Environmental indicators that can be used by managers to assess success of current efforts
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• Better ranking methodologies to evaluate cancer and non-cancer health effects and combine the
ranking results with population data and display the results using Geographic Information
System technologies
• Toxicological, bioavailability and bioconcentration information concerning the speciation of
chromium and the associated health effects. Other issues concern bioavailability and
bioconcentration of these chemicals.
• Better methodologies for assessing risks from complex chemical mixtures.
• Evaluation of indirect exposure assessment methodologies.
• Methods for analyzing indoor air exposure and contributions to indoor air from outdoor
contaminants.
• Consistent Agency policy on assessment and management of exposure source contribution.
Some offices, like the Office of Water, look at allocation of RfDs across exposure pathways
(e.g., drinking water and fish consumption), while other offices, like OPPTS, are not yet
looking at multiple exposure (e.g., dietary and household). As a result, EPA cannot evaluate
total exposure and the most significant exposure pathways and sources.
• International activities leading to standardization of hazard testing and classification and
assessment. EPA needs to harmonize activities across program, agencies and internationally.
• Areas not addressed by existing risk assessment guidelines, a process is needed to make
interim Agency-consensus decisions. Examples, include risk assessment of PAHs, PCBs, less-
than-lifetime exposures, complex or multiple media exposures, use of Monte Carlo simulations
for exposure assessments.
For ecological assessments, methods are required in the following areas:
• Specific guidelines and criteria for developing ecological risk assessments,
• Biological indicators and criteria for wetlands.
Support of the external environmental research community needs (i.e., academic grants). In
the area of GIS we have used grants to state agencies and local universities to develop necessary data
for the program. It is important for the Agency to develop closer ties with the environmental research
community to ensure a sharing of ideas, scientific information and expertise. To accomplish this,
additional funds need to be made available to award to these research groups.
Future needs. For the next 10 to 15 years, we see the need for better coordination among the
various portions of ORD and the development of appropriate computer applications to support regional
decisions. We also see the need for the laboratories to continue to evolve to include the latest scientific
knowledge and quality science.
Over the coming 10 to 15 years as the scientific disciplines supporting risk assessment continue to
expand, it is important for the Agency to be able to incorporate the latest scientific information in a
more timely manner. Using the Science Policy Council, the Science Advisory Board, and the Agency's
scientific expertise, it is essential that we develop a pro-active approach to incorporate the latest
scientific information in a timely manner. It is also essential that we provide the opportunity for
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Agency scientists to share information and the flexibility to keep abreast of the latest scientific data
and information through attending scientific meetings, sabbaticals, and publication in scientific
journals.
In considering peer-review we need to keep the following issues in mind:
• We need to continue to support the scientific development of our staff so that their credentials
reflect the current scientific expertise and they serve as peer reviewers,
We need to develop our own expertise to peer review documents within the regions and better
coordinate with Headquarters program offices, and with the states.
• We need to consider resources to support external peer reviews. For example, the external peer
review of the WTI risk assessment workplan cost $130,000. If we intend to use this
mechanism, it is essential that adequate funds be made available to access these diverse
groups.
We also need to develop better relations with other federal agencies, states and academia to
identify scientists that can aid peer review of specific documents and serve as external peer
reviewers. The Science Advisory Board currently addresses this need for major projects
however resources of the SAB preclude using this organization for all projects. It is important
to identify other scientists outside of the SAB that can provide review of specific topics on an
as needed basis. This will help to alleviate the burdens on the SAB members and identify
potential future candidates for the SAB.
• It is essential that we build peer review into the process early to prevent completion of projects
that do not meet the original needs of the project. Building relationships with the peer-
reviewers early in the project, providing updates and other opportunities for evaluation during
the project will help to ensure that the best science is included in the project.
What the Agency Should Be Doing
Unfortunately, many of these projects are long-term and results will not be available in the
foreseeable future. One problem is that while the research is carried out the regions need to make site-
specific decisions. To address this need it is important that mechanisms be developed for short-term
research projects possibly using university cooperative agreements. In addition, it is important to
develop mechanisms, such as the Science Policy Council, that can address interim policy decisions
while the research continues.
It is important to provide the regions with the flexibility to use existing contract and cooperative
agreements to identify specific research needs and develop workplans and programs to meet these
needs.
ORD's current mission leads it first to pursue research. Other functions such as quality assurance,
methods development, multilaboratory validation, etc., are slighted in staffing and funding. From a
regional perspective, technical assistance functions—which ORD views as secondary—are equally or
even more important to accomplishing Agency objectives.
Co
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One way to address this problem is to split the non-research support from the research funding
base. Cross-program efforts such as quality assurance, methods development, monitoring, and other
technical and policy support should have separate funding.
EPA's Role in the Fundamental Environmental Research
I see EPA's role as a leader in the development of regulatory methodologies for assessing human
health and ecological effects from exposure to chemicals in the environment. EPA must develop the
technologies needed to assess the fate and transport of chemicals in the environment and to develop
models to accurately predict the fate of chemicals, the results of which can be used by managers to
make policy decisions.
In addition, it is also important for EPA continue to coordinate with other federal agencies
(National Institutes of Environmental Health Sciences, National Toxicology Program, Agency for
Toxic Substances and Disease Registry, National Centers for Health Statistics, National Institutes of
Health, etc.) to share information, coordinate research programs, and ensure against duplication of
efforts.
Quality Control Authority
The region should set, implement, and audit standards for assessing the quality of EPA scientific
and technical decisions. This can be accomplished using the mechanisms of the peer-review process
within the region. In cases where additional expertise coordinated reviews through Headquarters
program offices and other regions are extremely important. Access to resources to involve appropriate
HQ and other regional staff in the review is important to ensure that documents and workplans are
evaluated in a timely manner.
For analyses on the cutting edge of the science, it is also important for the regions to have better
access to the Science Advisory Board and external peer-review mechanisms where appropriate. It is
essential, that the regions have access to these peer-review mechanisms (internal and external) during
all phases of the project (i.e., workplan stage, performance, and post-review) to ensure that the project
reflects the best available scientific expertise.
Federal Employee Functions
It is essential that EPA scientists carry out their review and development activities with integrity
and the ability to access the best available scientific information. It is important that Agency scientists
have the ability to share information with other scientists (inside and outside the Agency) on issues
that are on the cutting edge.
It is also important to keep in mind that Agency staff have inherent government functions that
cannot be delegated to non-EPA staff—e.g., criminal enforcement, decision making, etc.
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Scientific and Technical Laboratories and Facilities
Interview Summary
Date of Interview: 23 December 1993
Person Interviewed: Michael Cook, Director, Office of Wastewater Enforcement and Compliance
(OWEC), Office of Water (OW)
EPA Personnel Conducting the Interview: Roger Cortesi
Scientific and Technical Issues
This office is responsible for NPDES permit issuance where authority has not been delegated to a
state, enforcement of NPDES regulations, and administration of the state's revolving fund for
municipal wastewater facility construction. The enforcement role will be shifting to Office of
Enforcement next year.
NPDES enforcement is based on self-reporting by permit holders. This function relies on accurate
analysis and reporting by permit holders. To help ensure accurate results, OWEC relies on ORD to
conduct annual performance evaluations of laboratories performing water analyses for permit holders.
OWEC has high-priority needs in the area of wet-weather runoff and wastewaster control
problems, such as with large animal feedlots, mine drainage, and combined stormwater overflows.
These areas will require $50 billion dollars worth of capital construction to address. Some research is
needed in order to make the best use of limited resources by the affected communities.
How Well Are These Needs Being Met?
ORD is thinking of phasing-out laboratory performance evaluations. If this occurs, it is not known
how data from permit holders can be QA'd, even after OE takes over the role.
ORD does not conduct much research for OW. A need exists to conduct research both in "hard" and
"soft" technologies for addressing wastewater and runoff problems, especially in light of the large
sums of money spent by federal and municipal governments on construction of control and treatment
facilities. Currently, the municipalities and such associations as the Water Environment Federation
have conducted their own research. However, there is little coordination between the various research
efforts. EPA should be coordinating these efforts and conducting some research of its own to increase
the effectiveness and efficiency of the available construction funds. ORD could be doing more in this
area. However, it has been difficult to get ORD to pay attention to OW's needs.
OW needs for peer-review are met mainly through one-to-one contacts with people in the
laboratories that OW people know. There is no institutional mechanism in place for peer-review.
Changes in Function and Structure
OW once operated a water laboratory in Cincinnati. This laboratory was very useful and supported
OW's needs.
The number of laboratories that EPA operates is surprising and there appears to be a great deal of
overlap. Some of this could be consolidated and focused to provide better use of resources.
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The regional laboratories are an asset and should be maintained, although they might be
consolidated and focused as well. They could be focused into Centers of Excellence, as has been
discussed. For example, Regions 3 and 8 have a great deal of expertise in biosolids management and
could become Centers for this knowledge.
The recent controversy over the roles of contractors versus Federal employees may have gone
overboard. And the actions EPA is taking in this regard may be the wrong move. They run counter to
what one sees in the private sector now, with closer partnerships between suppliers and customers.
Close working relationships are also part of the TQM philosophy.
What the Agency Should Be Doing
EPA must have a strong leadership role in environmental research, including some basic research.
However, EPA doesn't really have enough funds to conduct an extensive basic research program. Even
if EPA doesn't do some types of research, it should act to coordinate that research that is going on
outside of the Agency or the government.
The research community within EPA should listen to the needs of the regulators and try to meet
them. However, ORD does need some independence from the program offices to conduct leading-edge
research which may not have an immediate payoff. ORD should also be in touch with leading-edge
research outside of the Agency.
Future Scientific and Technical Needs
The OWEC would like to see more work done on bio-monitoring techniques and techniques for
assessing changes to habitats.
The OW needs a comprehensive and systematic way of characterizing the effects of single and
multiple effluent discharges and non-point discharges on aquatic systems. They need new types of
environmental indicators to tell whether programs are really making a difference or not. They would
like to build such environmental monitoring techniques into future permits.
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Scientific and Technical Laboratories and Facilities
Interview Summary
Date of Interview: 16 December 1993
Person Interviewed: Peter Cook, Deputy Director, Office of Ground Water and Drinking Water
EPA Personnel Conducting the Interview: Carl Gerber, Tom Pheiffer
Long-Term Data Needs
Data are needed for standard setting, for regulation, and on treatment processes. Two examples of
the use of data for standard setting are (1) to establish maximum contaminant levels and (2) to
determine if frequencies of occurrence of a particular contaminant are high enough to set a national
standard. For regulation, data are needed to determine the toxic end points (for example, cell culture
studies to do risk assessment). Some examples of treatment process data are Best Available Treatment
Technology, costs of treatment, and unit cost information. This office also needs a national data set for
ground water, including latitude/longitude, to identify sampling points.
Work with Other Laboratories
This office has worked with the treatment technology and engineering branches of the Cincinnati
laboratories on basic methods.
What the Agency Should Be Doing
Historically, this office has not gathered parametric data, but this could be done with electronic
data transfer. Systems could be set up to catch some data inconsistencies, e.g., lack of turbidity spikes
during a rainy season. Currently, data systems have minimal content, and current needs cannot be met
with the existing system. As a result, the Office of Ground Water and Drinking Water is developing
new analytical methods. The expectation is that industry would test the methods, an EPA audit could
certify that these methods meet standards, and data collection could be expanded.
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Scientific and Technical Laboratories and Facilities
Interview Summary
Date of Interview: 15 December 1993
Person Interviewed: Tudor Davies, Deputy Assistant Administrator for Water (Acting)
Others in Attendance: Margaret Stasikowski, Director, Health and Ecological Criteria Division
Arnold Kuzmack, Senior Advisor, Office of Science and Technology
EPA Personnel Conducting the Interview: Roger Cortesi, Carl Gerber, Tom Pheiffer
Scientific and Technical Issues
There is a need for all areas of scientific and technical data, technical assistance and support, risk
assessment, scientific and technical assessment, quality assurance, peer reviews, and scientific and
technical review of proposed regulations.
Industry now provides data because there is no in-house capacity for technical work.
Work with Other Laboratories
Work with the Health Effects Environmental Research Laboratory at Research Triangle Park (RTP)
on mechanisms of carcinogenicity and mechanisms of toxicity; risk assessment work is done at
Cincinnati.
OW works with the laboratories to drive technologies; health effects research is limited by the
money that ORD has.
OW has worked closely with laboratories at Ada, Duluth, Corvallis, Athens, Narragansett and
others; more scientist-to-scientist communication is needed.
The formal ORD research planning process is not helping the OW mission, but working directly
with the people at the laboratories who are interested in the issues has made a difference.
Resource constraints limit interactions with ORD laboratories, since the laboratories have not had
enough ORD funds to provide the technical assistance needed by OW. Perception is that ORD has a
hidden agenda to move resources into more general areas.
Access to Data
OW needs to develop methods to measure and identify microbiological problems (needs are
identified, funding is not) and to develop indicator methods.
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Long-Term Data Needs
Perhaps funding for short-term research and basic and applied research could be separately
identified; EPA may cut back on some areas, but it should not eliminate anything (e.g.,
microbiologists).
With many needs, how should priorities be set?
OW has felt excluded from the decision process.
Changes in Function and Structure
Each region should have a laboratory capability, but the question is, do they need to have the same
capability?
Regional laboratories should be looked upon by the states as supplements to what the states can
do.
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Scientific and Technical Laboratories and Facilities
Interview Summary
Date of Interview: 15 December 1993
Person Interviewed: Scott Fulton, Deputy Assistant Administrator for Enforcement
Others in Attendance: Earl Devaney
EPA Personnel Conducting the Interview: Roger Cortesi, Tom Pheiffer
Scientific and Technical Needs
The National Enforcement Investigations Center (NEIC) is used to support the development of
criminal cases. EPA has a memorandum of understanding with the FBI to provide them with technical
assistance. Evidence development must be performed in government laboratories, even if agencies have
to share laboratories. NEIC needs multimedia inspectors trained in how to design and implement
sampling plans.
How Well Are These Needs Being Met?
The number of criminal cases has doubled in the past two years and continues to increase rapidly.
The capacity at NEIC has been reached, and the regional laboratories have to handle some of the
workload. This introduces the potential problem of having eleven protocols which may lead to the lose
of cases. Because of the capacity problem, the FBI is turning to state and contract laboratories. The
FBI have considered setting up their own laboratory because they are very concerned about using a
variety of laboratories.
Changes in Function and Structure
To meet the need for capacity, bring the regional laboratories up to NEIC standards and put
greater reliance on the regional laboratories. Give NEIC the authority to have more formal
relationships with the regional laboratories and improve communications. NEIC needs to be under
enforcement. Through the recent Office of Enforcement reorganization, they are trying to do better
strategic planning.
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Scientific and Technical Laboratories and Faculties
Interview Summary
Date of Interview: 25 February 1994
Person Interviewed: Lynn Goldman, Assistant Administrator, Office of Prevention, Pesticides, and
Toxic Substances (OPPTS)
EPA Personnel Conducting the Interview: Roger Cortesi, Bettina Fletcher, Carl Gerber
Scientific and Technical Issues
Scientific and technical data are extremely important to OPPTS. There must be good data
generated with approved/certified methods., as well as a place to test these methods. Moreover, there is
a need for methods capable of rapid testing of multiple pesticides. The health effects of multiple
pesticides are not thoroughly understood as there may be both additive and contradictory effects.
There is also a need to address the assessment of household exposures to pesticides. Although risk
assessment techniques are improving there should be more efforts placed on understanding
noncarcinogenic effects and non-health risks such as risks to endangered species and the ecosystem.
This would translate to providing registrants of new pesticides with better guidance on assessing
ecological risks.
How Well Are These Needs Being Met?
OPPTS has had good experience with the ORD laboratories, in particular the laboratory in Las
Vegas, NV It does not the environmental services laboratories as much. OPPTS relies on ORD to
develop test techniques.
Changes in Function and Structure
There are problems with mixing research activities with support services. Usually, there is
preference for research work and clients needing services are made to feel unwanted. On the other
hand, when it comes to budget cuts, R&D is the first affected because it is undervalued and not readily
understood. To protect research, it must be in an organization separate from the services group.
Collocating state and EPA facilities may have some merit as it will increase collaboration. The
concept can also be expanded to include other federal agencies such as the FDA. However, it must be
understood that collocation does not necessarily mean sharing use of equipment. People don't want to
have others use their equipment. Hence, sharing of equipment should not be considered as the driving
force for laboratory consolidation.
Program offices do not have time to do independent research, but it is difficult to get into ORD's
priorities. Thus, a joint process is needed. Scientists need to have a long-range view of me programs
and an awareness of where the programs are going. Currently there is a disconnect between science
and policy. This affects the planning for research.
Program and research relationships work when you have good people. Rotational assignments are
needed to give the staff opportunity to be competent in both technical and policy matters.
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Excellent science in the Agency is not very visible. The Agency should showcase its scientific
expertise. More successful researchers should be given higher profile and visibility (the peer review
process helps in this regard). The Agency should move away from measuring performance in terms of
activities (e.g., no of permits granted). In addition, better ways should be explored for linking EPA
research activities with those being performed at other federal agencies.
Future Scientific and Technical Needs
There is a strong push towards developing lower risk agents (pesticides). However, work on this
area is not thoroughly planned. Regulating multiple pesticides can become a logistics nightmare. More
basic scientific studies on the effects of multiple pesticides are needed.
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Scientific and Technical Laboratories and Facilities
Interview Summary
Date of Interview: 24 February 1994
Person Interviewed: Ann Goode, Acting Assistant Administrator for Air and Radiation
EPA Personnel Conducting the Interview: Roger Cortesi, Carl Gerber
What EPA Should Be Doing?
Because of equipment needs and the resources being spread over so much, EPA can't monitor
industries. EPA needs to coordinate the laboratories and set goals for them. It should provide some
sort of balance between what is critical and what is more long term and do strategic planning.
A collaborative process for setting agendas is critical. The Office of Air and Radiation does both
top-down and bottom-up reviews. We look at developing goals based on the planning process, hoping
for more futuristic thinking. The Agency needs to collectively think ahead. The regions should include
states in the planning process.
Research Needs
I am not sure that research needs have been articulated. Before 1990, this office was focused on
just getting the regulations for the Clean Air Act. We are just now recognizing the problems. EPA not
been effective in developing a research agenda that will enable us to make tradeoffs between
economics and other goals.
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Scientific and Technical Laboratories and Facilities
Interview Summary
Date of Interview: 7 February 1994
Person Interviewed: William Hunt, Branch Chief, Monitoring and Reports, Technical Support
Division, Office of Air Quality Planning and Standards
EPA Personnel Conducting the Interview: Roger Cortesi, Bettina Fletcher, Carl Gerber
Scientific and Technical Issues
The EPA laboratory system is essential is an essential component of the national air monitoring
program. Past work by the EPA laboratories has helped achieve the "best data set in the world" of
ambient air quality. This data base is essential in developing air strategies as well as in taking
enforcement actions.
One of the vital, day-to-day activities involves the Federal Records and Equivalance Program. This
lab-based activity acts as the "court of last resort" in resolving technical issues and challenges from the
states and other public monitoring as well as from private parties, and in helping maintain a high
quality of monitoring activity. This activity is related to how quality assurance of the monitoring
network is to be maintained. This is not a formal function of ORD, yet it is in ORD that much of the
monitoring expertise resides.
How Well Are Current Needs Being Met?
One area requiring additional effort is the need for improved capability in measuring VOCs in
relation to attaining the ozone and meeting the ozone standards. However, the current ORD support for
this effort is too little, evidently as a result of competing priorities.
In another area, Title m requires that a research air quality network be developed. However, while
this is an ORD responsibility, only one station has been developed to date.
Changes in Function and Structure
The current method of setting ORD priorities using the Research Committee system requires a
heavy investment of time, but has not so far been successful in setting more appropriate research
priorities.
There appears to be a fragmentation of responsibilities in AREAL for monitoring. A reorganization
that would concentrate such activities into fewer entities would assist.
Other Concerns
Many of the ORD research staff are in the 50-year old age range. There is widespread concern that
in a few years there will be a relatively sudden loss of experience across ORD. It is essential that steps
be taken to develop a younger generation of researchers.
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Scientific and Technical Laboratories and Facilities
Interview Summary
Date of Interview: 6 April 1994
Person Interviewed: Floyd Kefford, Director, Bureau of Laboratories, Pennsylvania Department of
Environmental Resources
MITRE Personnel Conducting the Interview: George Bizzigotti
George Bizzigotti met on 6 April 1994 with Mr. Kefford, Samuel Harvey, and Paul Baker of the
Pennsylvania Department of Environmental Resources (PADER).
The PADER officials noted that there was a meeting of state laboratory staff every six months in
Region 3. They indicated that they saw the Regional laboratory location in Annapolis, MD as very
convenient for all the states in the region except West Virginia. Annapolis is within 300 miles of
Harrisburg, and travel costs generally do not exceed $200.00; these are thresholds that require approval
at higher levels in the Pennsylvania State government. If travel funds are limited, the trip to Annapolis
and back can be made in a single day. Annapolis is a medium sized city, so a variety of
accommodations are available at a reasonable price. The PADER officials stated that prices would be
too high in a large city, whereas choice would be limited in a small town; Annapolis is an attractive
compromise between the virtues of urban and rural areas. Finally, they stated that there were no
perceived disadvantages to the current location.
When asked whether obtaining services from other regional ESD laboratories would affect their
programs or projects, PADER officials indicated that they currently have a mobile laboratory program
that is supported by the Region 2 laboratory (where mobiles laboratories are a specialty area) because
Region 3 lacks this capability. They pointed out that given state restrictions on travel funds, it would
be impractical for them to travel to any EPA regional laboratories other than those in Regions 2 and 3.
They believed that they would lose a long-term close working relationship if forced to obtain services
from another laboratory. They would favor the development of ESD laboratory areas of specialization
in areas which they perceive are currently under-supported, such as air and radiation analyses.
PADER requests support from the EPA regional laboratory on a peer-to-peer basis. Depending on
the scope of a problem, PADER staff may contact laboratory staff directly (e.g., for discrete problems
of limited scope), or the Mr. Kefford will contact the laboratory director (e.g., for broad problems of
less well-defined scope).
PADER does not provide any funding for regional laboratory operations (except for the training
cooperative described below).
EPA regional laboratory does not solicit feedback from states concerning the services they provide.
Scientific and Technical Issues
PADER officials were dissatisfied with EPA policy concerning the following technical issues:
• Regulations that specify "home-built" laboratory apparatus that is not widely available
• Regulations that do not allow the use of improved technology (e.g., ICP-MS instruments).
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• Regulations that specify different methods to do essentially the same analysis for different
EPA programs
• The required use of CFC-113 in the method for oil and grease analysis. Production of this
solvent is being phased out under environmental treaties, but the program cannot agree on a
replacement.
• EPA-required methods that conflict with EPA pollution prevention initiatives.
PADER officials expressed the opinion that there is not enough communication between EPA
programs and analytical services providers, especially between those charged with obtaining
environmental samples and those charged with analyzing the samples. They noted that regulatory
methods are often not consistent between programs and that the state of the analytical art may be
incapable of meeting certain regulatory requirements. They also pointed out a perceived lack of
awareness within the region of work being performed at the EPA program and Office of Research and
Development laboratories which has led to an inability of the regional laboratory to provide the
desired support to state air and radiation analytical requirements.
PADER officials said EPA regional laboratories could provide the states better services by better
keeping up with technology. They noted that state and commercial laboratories often have more recent
technology than the EPA laboratory does, which impairs EPA's ability to provide up-to-date expertise.
How Well Are These Needs Being Met?
PADER officials indicated that the EPA region 3 laboratory was not responsive to the state's
needs. They believe that this is a direct result of heavy reliance on contractors; EPA personnel "just
don't run as many samples as they should to have the expertise" to provide expert technical assistance.
Changes in Function and Structure
PADER officials suggested that the regional laboratories should make less use of contractors. They
believe that regional personnel are burdened by contract management responsibilities, and have lost
technical capabilities as a result. EPA personnel should perform more of the routine laboratory work
so that when states encounter a problem they can contact an EPA worker with expertise and
experience in performing the analysis.
PADER officials expressed a preference for EPA laboratories split into a service component and
an R&D component under a single administrative entity. They believe that this will improve their
access to work now being conducted in program laboratories (e.g., air). PADER officials also believe
that EPA should unite analytical and sampling groups under the same administrative entity. They
suggested that all EPA laboratories should report to a single entity which should be able to raise the
level of visibility of analytical functions relative to sampling or programmatic functions, so that
analytical requirements are considered when regulations are promulgated. They stated that there is a
need for a single entity, because there should be a single analytical "voice" from scientists who are
actually using methods on a day-to-day basis; that voice should be heard when developing regulations
to improve the consistency between regulations. They repeated on several occasions their belief that
EPA staff who develop analytical methods are not responsible to the eventual users of those methods.
PADER officials pointed out that there is a coalition of practicing state laboratory scientists that
meets on the regional level. This group has succeeded in raising analytical concerns and have
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influenced regional programs. They pointed out that there is currently no national level EPA group that
meets to discuss analytical methodology and laboratory operations. PADER believes that there should
be a national forum of state environmental laboratory scientists to communicate such concerns at the
national program level. This would represent a change in the current top-down regulation of analytical
methodology.
What the Agency Should Be Doing
PADER officials stated that the following functions should be available at the EPA regional
laboratory:
• Support state quality assurance programs
• Provide analytical capabilities for high cost/low volume analyses, such as transmission electron
microscopy (for asbestos) and high-resolution gas chromatography/mass spectrometry (for
polychlorinated dibenzodioxins and furans). PADER officials maintain that it is not cost-
effective for individual states to maintain such capabilities.
• Share expertise in and the capability to perform all EPA-promulgated analytical methods
• Provide training in state-of-the-art analytical technology. PADER officials pointed out that
Region 3 has a training cooperative, under which each state provides funding and input
concerning topics of interest, and EPA administers the training program based on the priorities
expressed by all the states. This enables the states to obtain training more cost-effectively than
they could do individually. The state funding entitles each state to provide input on the
training priorities and to send their staff to training sessions.
• Provide technical assistance for analysis of samples which prove difficult to analyze using
standard methods, such as analysis of kepone and mirex in fish.
• Provide technical support in analysis of air samples. PADER officials stated that the EPA
Office of Air laboratory in North Carolina has this capability, but there appears to be little
interaction between program and regional laboratories.
PADER officials stated that they did not want to have EPA contractors provide analytical services
because contractors could go to work for the regulated community. PADER believes that government
employees should perform analyses, because the governmental employees provide institutional memory
independent of contract awards, as well as specific areas of expertise.
PADER officials believe that training could be contracted out, but should still be coordinated by
the EPA. They pointed out that contractors are often more expensive for analytical work because of
the added overhead and rigidity inherent in the contracting process. They believe that a significant
amount of experience is usually lost when contracts change.
Future Scientific and Technical Needs
PADER officials reiterated the need for analytical capabilities for asbestos and dioxins in drinking
water. They also stated that the region will need to develop a program to certify state drinking water
laboratories so that they in turn can certify other laboratories, as required by regulation. PADER is
currently operating under a waiver of the state certification requirement.
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Scientific and Technical Laboratories and Facilities
Interview Summary
Date of Interview: 20 December 1993
Person Interviewed: Walter Kovalick, Acting Deputy Assistant Administrator, Office of Solid
Waste and Emergency Response
EPA Personnel Conducting the Interview: Roger Cortesi
Others in Attendance: Thomas Pheiffer, Bettina Fletcher
Scientific and Technical Issues:
Budget for meeting EPA science needs will not grow and will never be enough to meet needs.
Insufficient coordination and connecting of the work done at each laboratory
In the area of establishing method equivalency, there is no one uniform process that is being
followed at EPA. For example, the Office of Air has a more formal method for establishing
equivalency while this is done more informally for Superfund sites.
Lead responsibilities in the development of new technologies must be assigned to the regional
offices. For example, action on requirements for pollution monitoring happens in the enforcement side
(permitting or cleanup action) of the process. The region's involvement (through meeting user's needs)
comes too late. They have no input hi defining the requirements.
Long-Term Data Needs:
ORD data requirements are mostly driven by regulations.
OSWER relationships with the regional laboratories are primarily in support of Superfund sites.
One important contributor to technical support success is that OSWER pays for the laboratory's
services to them (presumably this leads to better issues/needs definition and accountability).
Access to Data
Need an agency-wide system for getting information, e.g., determining equivalency of new
treatment methods with known and already accepted methods. [The Superfund program appears to be
the only one with a system for new methods development that works, but results don't get spread
around the agency.]
Changes in Function and Structure
A structure is needed to allow the agency to co-plan and co-execute scientific endeavors with other
federal agencies, such as NOAA, USGS, etc.
It may be useful to consider removing the engineering research functions from ORD and creating
research centers as part of the program offices or use the "Centers for Excellence" concept for regional
laboratories with clear accountability for meeting the agency's science research needs.
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What the Agency Should Be Doing
Agency should consider establishing environmental research as a separate discipline, but simila to
the NTH model, to focus mainly on research without worrying about specific outcomes or outputs.
[ORD does not cultivate a wide body of research efforts.]
Other Comments:
The technical support system is working very well, especially with Superfund activities.
"Selective networking" seems to be the norm of doing buisness. [this can lead to underutilization
of the laboratories' capabilities.]
The program offices are "disenfranchised" by ORD's issue planning process. The task of
coordinating issues is a nightmare. ORD deals with too many issues, many of which are disconnected
from OSWER's needs.
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Scientific and Technical Laboratories and Facilities
Interview Summary
Date of Interview: 17 December 1993
Person Interviewed: Jerry Kurtzweg, Director, Office of Program Management Operations, Office
of Air and Radiation (OAR)
EPA Personnel Conducting the Interview: Roger Cortesi, Tom Pheiffer
Scientific and Technical Issues
This office develops strategic plans and budgets for the Office of Air and Radiation (OAR) and
reviews various inputs from other program offices within the context of the OAR policies. This office
also participates in standards setting, guidance development, and regulatory rulemaking.
OAR has its own laboratories for mobile source research, development, testing, and evaluation.
OAR also does research in radiation, both nuclear and electromagnetic.
Lack of resources is a problem. It forces OAR to focus on the most pressing needs while other
needs are deferred. The Clean Air Act imposed several new research or standards development
requirements. For example, the Ann Arbor laboratory is only working on Phase I standards. They
currently don't have the funding or staffing to work Phase n and non-vehicle emission standards.
OAR has difficulty keeping testing equipment up to date in laboratories. This is especially a
problem with newer standards that are exceeding current technology capabilities. It is also important to
keep abreast and maintain credibility with the regulated industries.
Work with Other Laboratories
OAR receives some support from ORD, mainly in the areas of stationary sources and in
development of criteria documents for ambient air standards. They also look to ORD for some new
methods and instrumentation, particularly for ambient and stationary source monitoring.
Changes in Function and Structure
Currently, there is a tension between research needs and program support needs. These areas
should be separated with research guided by legislative requirements. The development of monitoring
instrumentation should be somewhat insulated from program demands. However, standards
development needs closer ties to programs.
EPA must decide if it wants to have a world-class laboratory system for a few things or a less-
than-world-class system for a lot of things. EPA must have capability to do research, development,
testing, and evaluation in some areas, but maybe not all.
Future Scientific and Technical Needs
OAR requires resources to upgrade facilities and equipment in order to maintain parity with
capabilities of manufacturer's laboratories and to ensure continued compliance with increasingly
stringent emission standards.
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Scientific and Technical Laboratories and Facilities
Interview Summary
Date of Interview: 15 February 1994
Person Interviewed: Stan Laskowski, Acting Regional Administrator, Region 3
Others in Attendance: Greene A. Jones, Environmental Services Director, Region 3
EPA Personnel Conducting the Interview: Roger Cortesi, Bettina Fletcher, Tom Pheiffer
Scientific and Technical Needs
In general, the regional laboratories do a fine job.
Programs need support information from the labs. The D.C. water supply problem is a good
example. The current test for detecting cryptosporidium takes about 48 hours. A more immediate
analytic technique for detecting cryptosporidium would permit more real time decision making.
In the area of air toxics, there is a need to project and assess the combined impact of a suite of air
pollutants over time on a population group. This is especially relevant in terms of environmental
justice issues. What is the impact on children, sensitive groups, or minority subpopulations of different
contaminants?
Non-cancer health impacts continue to be an area of research need.
Standard methods for substances that are being regulated need to be developed Include a
mechanism to establish equivalency between methods used by the Federal labs and those used by state
labs. Need a sound and scientifically supportable data base for decision making.
Establish a centrally located expertise that could be available continuously to respond to health
emergencies at any location in the country.
Changes in Function and Structure
It is not obvious that a great restructuring of the lab system is needed.
The existing distinction between the ORD labs and the ESD labs should be maintained. These
organizations fulfill fundamentally different functions.
ORD research should be more oriented to the real world, it should be motivated by the
requirement to respond to regional needs-Q/A, sampling, compliance monitoring. The feeling in the
region is that ORD is a hard system to crack to get the methods needed.
Taking action on customer feedback may be more useful than any organizational restructuring
effort. ORD should improve its customer orientation and view the region as a customer. An ongoing
customer survey would provide ORD management with continual feedback on status, relevance, and
quality of ORD products.
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Nonetheless, ORD has been very helpful on a variety of issues including biodiversity and
wetlands.
Geographical orientation is not the issue. We can keep in touch through electronic
communications. On the whole, if the need and service can be matched with a nearby laboratory, it
would be preferable to use the nearby facility, but there is not enough distinction to justify a
reorganization along geographical lines.
ORD should be pursuing innovative technological solutions that could provide big leverage if a
breakthrough is achieved.
There is a tradeoff between establishing large central labs, which can offer efficiency in mass
production, and maintaining smaller more localized ones, which are closer to their customers.
Currently, lab directors have a good relationship with their customers.
Some regional labs have developed specialties to reflect particular needs in their region. These
specialties are a resource for the entire agency. There should be a way to budget for and access these
resources without being penalized.
The regions should have a core base of positions that they can dedicate to the BSD labs over time.
Say, a fixed core of positions with a five-year guarantee of stability would avoid the annual
bloodletting.
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Scientific and Technical Laboratories and Facilities
Interview Summary
Date of Interview: 13 December 1993
Person Interviewed: Susan Lepow, Associate General Counsel for Water
EPA Personnel Conducting Interview: Roger Cortesi, Bettina Fletcher, Carl Gerber, Tom Pheiffer
Scientific and Technical Issues
Scientific and technical data in support of rulemaking must be prepared well enough to hold up in
court, and timeliness of the availability of data is critical to meet court schedules. EPA is obliged to
move ahead on cases based on the data that are available. Quality assurance records are often
requested, and if requested, they must be presented and stand up to challenges.
How Well Are These Needs Being Met?
Needs for high-quality data on time are being met better today than in the early 1970s when poor
data and sloppy records resulted in loss of many cases.
Changes in Function and Structure
More emphasis on planning and establishing priorities would be helpful. The Office of General
Counsel (OGC), Assistant Administrator for Water (OW) and ORD need to become involved early in
the process. ORD labs need to understand that once the court schedules are set, they must be met.
Going back for time extension is more difficult than initially setting a realistic schedule and can result
in a hostile court environment. Missing court deadlines has also led Congress to issue an increasing
number of statutory deadlines.
Future Scientific and Technical Needs
Data needs in the future will be similar to those of the past, but industry is becoming more
sophisticated in its challenges. Therefore, the sufficiency and quality of the data will have to improve
if EPA is to meet more stringent challenges. In addition, it is becoming increasingly important to
articulate the benefits of the rule to decision makers and to have technical support for these benefits.
EPA needs to develop pollution prevention technologies since industry has not been very innovative in
this area. Environmental justice and equity are gaining attention and will lead to a need for new and
additional types of data.
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Scientific and Technical Laboratories and Facilities
Interview Summary
Date of Interview: 16 December 1993
Person Interviewed: Henry Longest, Director, Office of Emergency and Remedial Response
(Superfund), Office of Solid Waste and Emergency Response (OSWER)
Others in Attendance: Larry Reed, Director, Hazardous Site Evaluation Division; Hans Crump-
Wiesner, Chief, Analytical Operations Branch
EPA Personnel Conducting Interview: Roger Cortesi, Bettina Fletcher, Carl Gerber, Tom Pheiffer
Specific Scientific and Technical Needs
• Support is being obtained from the Ada laboratory on hazardous waste in ground water.
The Duluth laboratory is needed for its expertise in cold water fisheries.
• Guidelines for risk assessment are needed.
• The top issue is risk—not health risk, but more ecological risk, fate and transport. Help is
needed in basic long-range science, especially ground water research
Work with Other Laboratories
• The Analytical Services Advisory Committee can help determine roles of laboratories.
• Method development is performed by the Environmental Monitoring Systems Laboratory
(EMSL/Cincinnati).
Changes in Function and Structure
• PA needs its regional laboratories, and they should report to an Assistant Administrator.
• Superfund does not need its own laboratories; preference for EPA staff, but no funds available.
• Smaller regions need to be able to link to other laboratories.
A combination of the regulatory laboratories with other laboratories, into a centers-of-
excellence structure should be considered; there should be a unification of functions, such as
methods and QA/QC development to serve all programs.
Data Quality
Environmental Services Division laboratories review data on sites and direct support to CLP.
• If laboratory contracts out work, the number of federal full-time employees (FTEs) is reduced.
• The expansion of laboratory certification will increase data quality. The contract laboratory
program (CLP) is an indirect QA/QC program, and makes a bad contractor easier to spot.
What the Agency Should Be Doing
• Develop a new priority pollutant list.
• Develop and apply new technologies to Superfund sites (cluster concepts, lead and toxics,
groups of related chemicals).
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Scientific and Technical Laboratories and Facilities
Interview Summary
Date of Interview: 21 December 1993
Person Interviewed: Jack McGraw, Regional Administrator (Acting), Region 8
Others in Attendance: Kerry Clough, Deputy Regional Administrator (Acting), Region 8
EPA Personnel Conducting Interview: Roger Cortesi, Bettina Fletcher, Carl Gerber, Tom Pheiffer
Specific Scientific and Technical Needs
• Region can't contract for laboratory support.
• Major concerns: water activity, protocols, equipment, capacity under drinking water standards
Access to Data
• Needs are being met well now.
• Good production-oriented data from all laboratories, inside and out.
• Are we getting good quality at a good cost?
• Are we running too many parameters for the level of decision?
• ORD laboratories are research institutions; they address tomorrow's problems.
• ESD and National Enforcement Investigation Center (NEIC) address today's needs.
Data Quality
• There is no question on data quality, but there may be vulnerability.
• Samples are taken by contractors under direction of a government employee.
• A government employee decides where samples are to be taken.
Changes in Function and Structure
• ESD has QA and monitoring responsibilities around the country.
• NEIC would like to do all their analyses themselves.
• Regional laboratories should have expertise in some particular area.
• ESDs would have more stature under an assistant administrator.
• The regional scientist program could be the focus of the centers of excellence to show the
regional chemists new techniques.
Work with Other Laboratories
There is almost no relationship with other laboratories.
Long-Term Data Needs
• Bioassay
• Risk assessment
• Research in real-time for air monitoring
Definition of data needs for Superfund's new, long-term contracting strategy
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Scientific and Technical Laboratories and Facilities
Interview Summary
Date of Interview: 15 December 1993
Person Interviewed: Richard Morgenstern, Assistant Administrator for Policy, Planning and
Evaluation (OPPE)
EPA Personnel Conducting Interview: Roger Cortesi, Bettina Fletcher, Carl Gerber, Thomas
Pheiffer
Scientific and Technical Issues
OPPE has cross-cutting responsibility, dealing with air, water, waste, and global climate. The work
of this office rarely relies on original data nor does it design experiments; rather, it is usually involved
with extracting some existing scientific data to derive policy information. Most of the office's current
information needs involve a quick response
OPPE has a climate program that needs scientific support. The program has attempted to
coordinate with ORD in the past, but the results have been uneven and the support ineffective.
Specification of information needs by this office to the laboratories is limited. However, OPPE does
have considerable contact with the mobile source laboratory in Ann Arbor, in particular.
Long-Term Data Needs
OPPE tries to identify decisions that may be required in the future and to project what data will be
required to inform these future decisions. An example may be the long-term damages of global
warming, particularly the scope of the consequences and the need for better information on the
possible damages. ORD seems to be slow in responding to this need. In areas where ORD is not the
leading research entity, ORD may more effectively apply its resources in results analysis rather than
toward developing the research itself. OPPE would benefit from research results on problems we
define now, even though the research may not yield results for more than two years. There is not a
high payoff for OPPE to influence short-term focused decisions.
The primary client for specific media research will always be the respective media office.
However, in the climate area, OPPE is becoming a major client of the Air office.
Access to Data
OPPE is fairly adept at using contractors, and cooperative and interagency agreements to acquire
timely information, although the contracting problems often interfere. The office relies on the same
mechanisms to ensure the reliability of data acquired in this way as it does for internally derived data,
i.e., largely formal and informal peer review processes. Occasionally, OPPE will rely on a laboratory
employee to contribute to a peer review if that individual is in possession of a particular expertise.
Changes in Function and Structure
Because EPA has 38 laboratories, there must be some mechanism to inform all offices throughout
the Agency about what is going on at these facilities. Perhaps new information technologies might
facilitate that communication; using the internet is one technology that might help.
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OPPE is not especially aware of what is going on in the regional support laboratories. This is
symptomatic of a broader problem that relates to the sheer amount of activity undertaken in the
laboratory system. OPPE personnel could spend a disproportionate amount of their time coordinating
with all of the laboratories just to stay abreast, rather than making progress toward accomplishing the
specific objectives of the office, that is, developing policy guidance.
The laboratory system needs to provide an accountable mechanism for expression of the needs of
the office both in the 6-month and the 2-year timeframe. This is now accomplished through an
informal process.
What the Agency Should Be Doing
• EPA needs to define its expertise and specialize in it.
• ORD should be technically knowledgeable and policy-relevant. ORD work should have a
policy link without sacrificing technical quality.
• Several long-term programs (e.g., EMAP and NHEXAS) are apparently resource-intensive, but
may be developing data that is in need of a client. Some of this information may or may not
be of use in the future since a great deal is already known about health impacts.
• The federal work force is accountable and responsible to the public and the taxpayer; their
motives are not compromised by private gain incentives.
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Scientific and Technical Laboratories and Facilities
Interview Summary
Date of Interview: 10 March 1994
Person Interviewed: Jean Nelson, General Counsel
EPA Personnel Conducting the Interview: Roger Cortesi, Tom Pheiffer
Needs of Office of General Counsel
As the lawyers for the agency, with the regulatory issues and lawsuits that arise from that, we are
dependent on a good, sound science base for what we do. We focus on information being solid and
timely. The timeliness is important for the creditability of the agency. The lawyers are responsible for
faithfully executing the laws and meeting the deadlines. We are dependent on you all doing as much
as possible up front in a timely manner. Our credibility with the court system and the lawyers that go
up against us, and the public, is lessened by being late. Timeliness is one of the most important
factors.
There are two separate parts of the science question. One is, do you have the data you need to
make the decision? The second point is, when studying a case, it seems that you would like to know
two things—that all the relevant data have been looked at and is it sound science? I am more focused
on the second point and whether that is a high enough standard. One of the things that we have
identified in terms of meeting the perceived needs of our clients in the agency is that maybe we need
more exchange with ORD as a client.
We are so dependent on the record that is built, and our work is dependent on timely science on
the record. The work must be defensible. The courts still give a fair amount of deference to the agency
if we can show that there is a good basis for the information.
We worry that we spend a lot of time being rule writers, and we could spend more time on the up
front work if we didn't have to spend time correcting the English. If the goal of the agency is to have
quality rules, then we should do back end as well as front end work.
RC - Explaining why you did what you did is very helpful.
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Scientific and Technical Laboratories and Facilities
Interview Summary
Date of Interview: 14 February 1994
Person Interviewed: Margo Oge, Director, Office of Radiation and Indoor Air (ORIA), Office of
Air and Radiation (OAR)
EPA Personnel Conducting the Interview: Roger Cortesi
Mr. Cortesi provided some background on why this interview was conducted, and agreed to allow the
interview to proceed outside the planned agenda.
Scientific and Technical Issues
ORIA would like to have the benefit of ORD experience in the areas of modeling, risk assessment,
guidelines for QA and QC, and methods standardization. Guidelines for QA and QC should be
provided by ORD for other labs to follow.
How Well Are These Needs Being Met?
ORIA would like ORD to play more of a role in the radiation program. They feel that ORD
currently provides no support to ORIA so that the program office has had to do their own work.
ORIA finds it troubling that ORD has no capacity for peer review of program office science, stating
that ORD has disinvested in this area during the last 10 years.
ORIA is developing radionuclide cleanup standards under the Atomic Energy Act, and also needs
QA/QC support for this activity. ORIA believes that ORD has the necessary depth and breadth of
scientific knowledge for this task.
ORIA is also responsible for the indoor air program and would like ORD research in certain areas
of this program, especially the area of multiple chemical sensitivity. ORIA's needs in the indoor air
area run more towards research than to program support. The regions are not doing much work in this
area. Generally, ORD support for indoor air has been good.
ORIA has 2 field facilities in Montgomery, AL and Las Vegas, NV supporting their program.
Both facilities evaluate the proficiency of independent radon measurement contractors and radon
measurement kits. This evaluation has become a de facto certification program, as it is often required
by state governments. Both facilities provide support for rulemaking and for Superfund. The
Montgomery facility has emergency response monitors of background levels in air, water, and milk.
Montgomery does not have enough capacity to analyses for the regions and states under Superfund;
both staff and funding are limiting factors. Private sector capability is difficult to judge because of the
lack of standard methods and QA/QC procedures.
ORD once supported radon remediation, but that is being defunded. ORD provides no support for
non-ionizing radiation.
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Changes in Function and Structure
ORIA does not understand how ORD makes decisions concerning their priorities. ORIA believes
that program offices should be given more information about ORD's priority-setting process; they
don't know whether they could do it better because it's such a mystery to them.
ORIA suggested asking how we get a faster response (much less than 2-3 years) center of
excellence in ORD.
What the Agency Should Be Doing
ORIA believes that spending on research for the indoor air program should be higher than $8
million.
ORD has provided good support in the area of radon risk assessment, serving as a referee between
the program office and other agencies. ORIA hopes that ORD will play such a role more often.
ORD should set aside some FTEs for radiation.
Future Scientific and Technical Needs
• Framework for QA/QC (similar to that for the drinking water program)
• Increased capacity for analytical work (mostly Superfund; this is necessary because there is no
certification for radiation labs and the quality of results from commercial labs has been poor)
• Technical support for cleanup standards review under the Atomic Energy Act for oversight of
DOE work
• Research on multiple chemical sensitivity and mixtures for indoor air (joint action with
ATSDR and DOE)
• Indoor radon study (similar to the work on second-hand smoke)
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Scientific and Technical Laboratories and Facilities
Interview Summary
Date of Interview: 11 March 1994
Person Interviewed: Robert Perciasepe, Assistant Administrator for Water
EPA Personnel Conducting the Interview: Roger Cortesi, Bettina Fletcher, Carl Gerber
Scientific and Technical Issues
The Agency is focused on chemistry, but the water program is focused on biology. They should
have predicted the cryptosporidium crisis and have had the scientific knowledge to respond quickly.
If EPA gets the states to take responsibility for more activities, the Agency must provide them
guidance to assure consistent, high quality activities;
The quality and quantity of scientific data available for rulemaking decisions varies from rule to
rule implying room for improvement.
Changes in Function and Structure
It is appropriate for the Agency to contract out science to the experts, but the Agency should not
be in the position of having to rely on consultants. The Agency should guard against losing the in-
house ability to judge the science conducts for it.
Future Scientific and Technical Needs
• An emerging need is for ecosystem indicators.
• The agency needs more expertise in microbiology.
• Science should be driving the regulations, but currently regulations are ahead of the science.
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Scientific and Technical Laboratories and Facilities
Interview Summary
Date of Interview: 17 December 1993
Person Interviewed: William Rice, Regional Administrator (Acting), Region 7
Others in Attendance: Charles Kinsley
EPA Personnel Conducting Interview: Roger Cortesi, Bettina Fletcher, Carl Gerber, Tom Pheiffer
Scientific and Technical Issues
The regional BSD supports a variety of activities within the region, including sample collection
and analyses, field investigations, program support, and state laboratory capacity development. Region
7's ESD also conducts removal actions under the Superfund program.
The Laboratory Study needs to distinguish between the roles of the regional ESDs and the ORD
laboratories. ORD has charter to do research in certain areas regardless of program needs. This sets up
a tug-of-war between programs needs and research needs. The regional ESDs, on the other hand, must
support program functions in the regions.
The regional administrators need to have regional ESDs, particularly for quick response to
environmental emergencies, for example, such as the recent Midwest flooding. Having people in the
laboratory with field experience allows them to respond quickly and confidently to incidents. It also
allows better communication and control.
Also, having experienced laboratory personnel in the regional office allows them to do better QA
of data and to aid states in developing their QA plans. Also, it helps them to develop analytical
capacity and expertise in the states.
The regional ESDs also have a role in enforcement. ESD personnel perform inspections, train
inspectors, conduct sample analyses, and testify in court. Region 7 believes it gives EPA added
credibility in court to have experienced and knowledgeable laboratory and field personnel. The
attorneys are less confident when non-EPA employees are involved in developing a case. Region 7
believes that ESDs could be more useful in enforcement if standardized sampling and analysis
protocols were developed and certification, QA/QC, and audit procedures were implemented Agency-
wide. The NEIC is not the only qualified laboratory to conduct enforcement analysis. However, for
ESDs to increase their enforcement support additional resources would be needed, particularly for
criminal investigations.
Work with Other Laboratories
Methods development is important for regional ESDs, especially in areas where technology is
changing rapidly. ORD is source for methods development for the region. Methods currently take
about 4 to 5 years to develop, which is too long. ORD needs to work with ESD directors to determine
needs. Response of ORD to ESD needs is very slow. ESDs appear to be given lower priority and don't
have the funds to get ORD's attention.
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Changes in Function and Structure
ORD is so technically diverse and geographically dispersed that scientists in the region do not
know who is doing what or who they should contact for help on a specific problem. It is becoming
increasingly difficult to keep up with all of the activities in ORD. Currently, Region 7 does not have
anyone in the ORD regional scientist position and the ORD Technical Assistance Book is not a good
means of communicating the capabilities and activities of ORD to regional scientists. A better method
for communicating ORD's activities and capabilities to the regions would be to return to analytical
work groups to force ORD and regions to sit down and talk about specific issues and needs. There
needs to be more face-to-face contact. However, the Agency would have to provide the budget for it,
especially travel money.
In response to the suggestion that the regional laboratories might be organized as centers of
excellence, they thought that it made a lot of sense. However, currently the regional ESDs have no
mechanism for charging clients in other regions or programs for work that they perform. They simply
absorb the cost. Under a center-of-excellence concept, a resource-trading mechanism would need to be
found.
Future Scientific and Technical Needs
• Better explanation of basis for regulations. Need to put science in understandable context for
states and public.
• Better ways of treating ground water where it is not necessary or possible to clean up
contamination to a pristine state
• Lower cost of pollution control for small communities
• Guidance to allow communities to make risk decisions on their own
• Better comparative risk analysis techniques—more information needed before regions can talk
to states about this
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Scientific and Technical Laboratories and Facilities
Interview Summary
Date of Interview: 21 December 1993
Person Interviewed: John Seitz, Director, Office of Air Quality Planning and Standards (OAQPS),
Office of Air and Radiation (OAR)
EPA Personnel Conducting the Interview: Roger Cortesi, Bettina Fletcher, Tom Pheiffer
Scientific and Technical Issues:
There is an immediate need for further examination of the health effects of PM10, and ozone, and
an assessment of the "189" trading scheme.
Testing is accomplished by non-EPA sources, although EPA sources are responsible for inhalation
testing.
Ozone modeling capabilities of OAR need to be improved and collaboration with other labs
pursued.
An objective, quantitative system is needed to define science and technology data gaps, rank these
needs, and facilitate efforts to meet them through prioritized allocation of resources.
Monitoring and long-term work in the area of particulates receive a lower priority.
Long-Term Data Needs
• Multimedia research is essential.
• Ecosystem-wide problems must be examined in a holistic approach.
• ORD should referee the multimedia assessment.
• Criteria and methods for plant and ambient monitoring should be developed.
• Encourage universities and private sector to fulfill long-term needs with EPA providing QA
and oversight.
Access to Data
There is no mechanism to permit ready identification and retrieval of useful work and expertise in
the lab system nor instruction on how to use it.
OAR coordinates with the NAIHS for information on health-related issues and with DOE for
global impact questions.
A strong technical relationship exists with the states through the monitoring networks.
Changes in Function and Structure
Areas of research must be chosen selectively and outside research leveraged carefully.
• Committee recommendations are overwhelmed by the politics of the process.
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• No changes in the ORD structure is recommended; research and program activities have a
useful cross-fertilization impact on one another.
• Program labs should be doing testing, certification, and implementation, while research and
QA should be centralized.
What the Agency Should Be Doing
• Labs must focus their expertise and do what they do best.
• ORD should ensure that all labs are producing quality data.
• Some ESD labs are good, while others are not so good; on average they perform at about a
"C" level.
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Scientific and Technical Laboratories and Facilities
Interview Summary
Date of Interview: 28 December 1993
Person Interviewed: Michael Shapiro, Office of Solid Waste
EPA Personnel Conducting the Interview: Roger Cortesi, Bettina Fletcher
Scientific and Technical Issues
• Need to develop partnerships with outside organizations.
• Establish balance between research (ORD) and program needs.
• Need to continue efforts to improve multi-pathway risk assessment methods.
• Massive shift of resources to projects like EMAP is diverting activities in support of program
needs.
Long-Term Data Needs
• Fundamental research is needed in support of ozone and PM10 standards.
• Need analytical methods that are species-specific and inexpensive.
• Large amount of work needs to be done in the air toxics program (in support of amendments
to Clean Air Act)—monitoring requirements and standards toxic air pollutants that are species-
specific; continuous monitoring systems, either remote or in-situ; noncarcinogenic effects of
toxic pollutants.
Access to Data
• ORD is not responsive to program needs—can't provide models needed by program office in
timely manner.
• Joint technical support centers program is working—provides opportunity for partnering
program and research people to address specific problems; center staff act as bridge between
program and research staff.
Changes in Function and Structure
• No strong need for major reshuffling of responsibilities.
• Moving the OAR laboratory (in Alabama) to ORD will be burdensome and will achieve no
gain in overall research.
• Engineering laboratory at RTF could be shifted to program office laboratory at Ann
Arbor—they have same functions.
• Improvements are needed in communicating needs—program office pressured to come up with
decisions; hard to get ORD, which is set on quality of science issues, to support program
office needs.
• Too many organizational hurdles in translating program priorities to laboratory-level work.
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What the Agency Should Be Doing
Strengthen relationships with other federal agencies—DOE is putting lots of money on
environmental research; EPA should get leverage for such relationships.
Other Comments:
Risk-based planning is not a tool for restructuring the Agency's work across programs, but it has
been useful in day-to-day priority decisions.
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Scientific and Technical Laboratories and Facilities
Interview Summary
Date of Interview: 28 December 1993
Persons Interviewed: Robert Wayland, Director, Office of Wetlands, Oceans and Watersheds
David Davis, Deputy Director, Office of Wetlands, Oceans and Watersheds
EPA Personnel Conducting the Interview: Roger Cortesi, Bettina Fletcher
Scientific and Technical Issues
Need to put emphasis on ecosystems
Long-Term Data Needs
• Ecosystem characterization
• Status and trends—to help formulate policies and programs
• Indicators—basic science needed to formulate indicators, such as environmental, management,
and monetary indicators, for use in goal-setting
• Routine operations monitoring, e.g., a water quality data system needed to collect and analyze
water samples; provide oversight of the state's monitoring process
• Water quality standards and assessments, e.g., meteorological modeling and sampling needed
to calculate total maximum daily loads of pollutants
Management and remediation techniques
Access to Data
Generally good support from other laboratories and research community (e.g., knowledge on
restoration technologies provided by ORD's Corvallis and Duluth laboratories)
Changes in Function and Structure
• Broaden ORD environmental research functions—more emphasis on gaining knowledge from
basic and applied research instead of purely technical support.
Enhance creative approaches for networking—currently Corvallis staff networks with other
laboratories to address regional needs and advance state of knowledge in certain areas. Also, in
the wetlands area, there is a person who serves as liaison so that programs and research efforts
are communicated to others.
• Changes needed to eliminate overlap of functions.
Structural changes needed—issue-based planning process is too elaborate; issues need to be
consolidated; there is lack of ownership; process is unwieldy.
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• Consider making EMAP a separate entity or integrate it with other ecological programs.
• Research programs should manage the external grants, not a central office (like OER?).
What the Agency Should Be Doing
Risk communication must focus on ecological risks, not just on health risks. Consider market
approaches to induce behavioral changes.
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Scientific and Technical Laboratories and Facilities
Interview Summary
Date of Interview: 22 December 1993
Person Interviewed: Richard Wilson, Director, Office of Mobile Sources (QMS), Office of Air and
Radiation
EPA Personnel Conducting Interview: Roger Cortesi, Bettina Fletcher, Carl Gerber, Tom Pheiffer
Scientific and Technical Issues
This office directs laboratories located in Ann Arbor, Michigan that conduct research,
development, testing, and evaluation related to controlling emissions from mobile sources. Laboratories
conduct fuels analysis, and automobile and truck testing for compliance with various clean air
regulations and standards. They work with the states to improve the states' vehicle inspection
capability. They contract out for in-use testing of automobiles. Because they rely heavily on
manufacturer self-testing data, they also conduct laboratory correlation studies to ensure that
manufacturers are accurately testing their own engines and vehicles. This capability gives EPA
leverage with the regulated manufacturers to ensure compliance with regulations. Lack of resources in
this area is a problem, particularly for new equipment to support compliance testing.
The OMS laboratories also conduct some development work. The purpose of this work is to test
and demonstrate the feasibility of innovative emissions-control technologies. They believe it is much
easier to convince industry to add new control technology if they can demonstrate its feasibility first. It
is important for EPA to maintain such a capability.
It is also important for EPA to have expertise in certain areas, such as advanced control
technologies or health effects of fuel additives, to be able to credibly and effectively explain and
defend its positions in developing and enforcing regulations.
Work with Other Laboratories
OMS has working relationship with the laboratory at Research Triangle Park, North Carolina.
OMS develops the standards for testing the vehicle. It relies on ORD to develop the instrumentation it
needs for compliance testing. A key element in such a relationship is to keep the laboratory focused on
the research issues needed to develop a basis for rulemaking. This office does not have much contact
with regional laboratories.
Changes in Function and Structure: No changes specifically identified.
Future Scientific and Technical Needs
Funding to purchase new equipment that will keep abreast of the regulated industry is critical. As
standards become more stringent and technology advances, access to the latest testing equipment will
become increasingly important for ensuring manufacturer compliance with Clean Air Act regulations
and standards. The focus in OMS is shifting to research in the area of health effects of fuel additives,
such as MTBE and manganese. Data and research are needed in this area. Also, it is important to be
able to explain to the public the scientific basis of any future regulations in this area.
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Scientific and Technical Laboratories and Facilities
Interview Summary
Date of Interview: 16 December 1993
Person Interviewed: John Wise, Deputy Regional Administrator, Region 9
EPA Personnel Conducting the Interview: Roger Cortesi, Carl Gerber, Tom Pheiffer
Scientific and Technical Needs
The focus of this region is on operational aspects such as the following:
• Ambient monitoring
• Compliance assessment
• Enforcement case development
• Remedial investigations
• Laboratory certification
• Technical assistance to state laboratories
• Quality assurance
The need for technical assistance to state laboratories is expected to increase over time. The
regional laboratory will continue to support regulatory functions and enforcement activities. The state
laboratories need the regional laboratory support for audits, methods developing, and capacity building.
How Well Are These Needs Met?
The region's basic needs are being met by the use the regional laboratories and contractors (CLP,
ESAT). However, there is increasing concern about CLP contractors' quality not keeping pace, in
addition to claims of fraud, and mismanagement. EPA could do the job better, faster, and cheaper.
EPA should invest in its own laboratory base for economic improvement and more benefit to the
public.
Functional Changes
The Agency needs to improve its planning activities (e.g., sampling plan development, design
monitoring, and data quality objectives). People in the field need protocols as guidance to optimize the
data-gathering and analysis efforts. A policy directive could increase the use of field screening
methods.
Changes in Structure
The suggestion was made to increase state capacity and invest in improving their performance
(provide training in new methods, help with quality assurance plans, develop protocols). Then let the
states handle wet chemistry and EPA handle the newer methods. An alternative offered was to network
EPA regional laboratories with each being the expert or center of excellence in a particular work area.
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Access to Data
EPA needs to improve its information transfer capability if its products are to reach EPA's
customers. This is a current weakness.
What the Agency Should Be Doing
• EPA should continue to develop methods for competent sampling and analysis in air and water
(for ecological risk assessment).
• Better field monitoring techniques should be provided.
• Work should continue on exposure assessments, particularly for children.
• Goals need to be prioritized. Long-term and short-term goals are always competing with each
other. The resolution has been compromise at both ends.
• Huge investments are needed in basic research. For years, ORD has been systematically
plundered. The whole range of research in the federal sector should be accessed to determine
where EPA can make significant contributions and then focus on only those areas. EPA should
be preeminent in the environmental research agenda.
• Continued investment is needed in the academic community, which has the responsibility for
exploratory research.
• Since regional laboratories don't have their own budgets, they should have a champion in
headquarters.
Research Functions Versus Technical Support Activities
A balance is needed between research functions and technical support activities. About 70 percent
of funding should go to ORD for fundamental research, while 30 percent should go to technical
support. The degree of integration between technical support and laboratory functions varies from
region to region, but Region 9 is well-connected to the program office laboratories (e.g., Ann Arbor
has helped them develop vehicle emission strategies).
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Scientific and Technical Laboratories and Facilities
Interview Summary
Date of Interview: 22 December 1993
Person Interviewed: Gerald Yamada, Principal Deputy General Counsel
EPA Personnel Conducting the Interview: Roger Cortesi, Bettina Fletcher, Carl Gerber
Scientific and Technical Issues
• Transfer and communication of technology—better communication links are necessary.
• A strong, objective research program is needed.
• Need strong science in-house to maintain credibility; current trend seems to cultivate "contract
managers" instead of scientists.
Long-Term Data Needs
• Data is needed to support rulemaking and negotiate regulatory schedules.
• Data to support rulemaking is generally adequate; challenge of data very rare.
Access to Data
This office does not get heavily involved in data collection; it relies on program offices to ensure
that data is of good quality and reliable.
Changes in Function and Structure
Should EPA reorganize, there should be an Office of Research and an Office of Environmental
Economics reporting directly to the Administrator.
What the Agency Should Be Doing
• Need to take a look at the economic impacts of regulations.
• Science must drive the regulatory agenda of the Agency.
Other Comments
• Misrepresentation of academic credentials by EPA employees happens periodically; this raises
credibility question for the Agency even though there is nothing wrong with the quality of
data.
• Although industry-generated data can be used to support rulemaking, the Agency must review
the data and ensure that they are reliable.
• Interagency agreements may be effective means of enhancing EPA's research capabilities, but
conflict of interest issue must be addressed.
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