EPA-AA-TSS-I/M-85-09
            EPA AUDITS OF STATE AND LOCAL
            INSPECTION/MAINTENANCE PROGRAMS
                          By:

                  Philip A. Lorang

                  Jane A. Armstrong

                  John M. Cabaniss, Jr.
This  paper  was  presented, at  78th  Annual  Meeting   and
Exhibition  of  the  Air  Pollution  .Control  Association  in
Detroit, Michigan, on June 18, 1985.
                Technical Support Staff
         Emission Control Technology Division
               Office of Mobile  Sources
              Office of  Air  and Radiation
         U.  S.  Environmental Protection Agency

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Abstract

     EPA AUDITS OF STATE AND LOCAL INSPECTION/MAINTENANCE PROGRAMS
     P.A.Lorang, J.A.  Armstrong, J.M.Cabaniss
     U.S.Environmental Protection Agency,  Ann Arbor,MI 48105


Many State  and local agencies  have  implemented vehicle  emissions
I/M  programs  in  the  last few  years.  EPA began  to audit  these
programs  in  federal  FY1984.  The  audit   process   for   I/M  was
developed in conjunction with STAPPA/ALAPCO; the  I/M audit became
part of  the National Air  Audit System in  FY1985.  Results of  the
I/M  audits   indicate  that  (1)  enforcement  is  a  problem  in some
programs with  sticker based enforcement;  (2) low  reported failure
rates  are  a problem  in  many  decentralized programs,  especially
those  that  -use   manual  analyzers,   and   in   some  centralized,
government  run programs;  (3) high waiver  rates are a  problem in
some programs,  both  centralized  and  decentralized; (4)  analyzer
quality  assurance  ranges from excellent in centralized,  contractor
programs  to   marginal   in   decentralized   programs with  manual
analyzers  and  in  some  centralized government  run  programs;  (5)
data analyses  are  not being  effectively  used in most programs to
monitor  and  improve  program performance  and  the  performance of
individual  inspection stations;  (6)  the quality of  I/M  repairs is
a problem,  to  some extent, in every program audited.  EPA believes
that the resolution of  these problems generally  rests  with each
State/local   I/M  program   developing   an   overall  I/M  quality
assurance  program  to  ensure  that  problems  are   identified  and
resolved in  a timely manner.  .

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     As  a  direct  result  of.  the survey/workshop  and  related
comments received from State and  local officials, EPA's  Office
of Mobile Sources  (QMS)  decided early in 1984 that there  was  a
definite need for a national  I/M  audit system and national  I/M
audit guidelines.  EPA  and State  and local agencies could  use
such an audit program   (1) to  ensure that statutory and  State
Implementation Plan  (SIP)  requirements  are being  met;  (2)  to
assist  in  developing  an  acceptable  level  of   I/M   program
guality; (3) to  account  for  the achievements,  shortcomings,  and
needs of  the various   I/M programs;   (4)  to  identify  programs
needing further  technical  support or  other  assistance;  and  (5)
to  identify technical issues  common  to  all  or  many  programs
which need further investigation.

     At the  time that QMS made this  decision, EPA's Office of
Air Quality  Planning and Standards (OAQPS) was in the midst of
a  cooperative   effort   with   the  State  and  Territorial  Air
Pollution Program  Administrators  (STAPPA)  and the  Association
of  Local  Air Pollution  Control  Officials (ALAPCO) to  develop
and  implement the  National Air Audit System  (NAAS).  The NAAS
was  being   developed  to   serve   generally  the  same  desired
objectives  for  the air  guality . management programs across  the
country.  In NAAS, the EPA Regional Offices are responsible for
conducting  the   individual  audits and. issuing  related  audit
reports, and OAQPS is  responsible for assembling national audit
results and issuing an annual national audit report.

     After   consultations  among   officials  of   STAPPA/ALAPCO,
OAQPS,  and  OMS,  it  was  decided that  the  best  approach  for
developing the I/M audit program would be  to  add  an I/M element
to  NAAS in  federal FY1985.   This necessitated  the development
of the national  I/M audit  guidelines  during federal FY1984.   In
keeping with the NAAS  process,  a STAPPA/ALAPCO I/M subcommittee
was  formed  to  work  with  OMS  in developing  the  national  I/M
audit  guidelines.   With  the  help  of  STAPPA/ALAPCO  and  I/M
officials around the  country who served as reviewers,  the  I/M
audit  guidelines  were  developed  on  schedule   and  appear  as
Chapter 6 of the National  Air Audit  System  Guidance  Manual  for
FY85   (EPA-450/2-84-008;   December,   1984).    The   I/M  audit
guidelines   were  developed   in   conformance  with  generally
accepted  government  auditing  standards  as  contained  in  the
report:   "Standards  for Audit  of Governmental  Organizations,
Programs, Activities,  and Functions,"  (U.S.  General Accounting
Office, 1981 Revision).

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     The FY1985  I/M  audit  schedule appears  in Table  3.   The
majority of  the FY1985  I/M audits  will involve  decentralized
programs (six of eight).   All of the programs,  except the Texas
(Harris  County)  program,  will have  been in  operation  for  at
least  one  year  at  the  time  of the  audits.   In  the  case  of
Texas,  the  program  will  have been   in  operation  only  nine
months.   The  Texas  program  was  originally  included   in  the
FY1985  audit  schedule  because  of  its planned  implementation
date of April 1984.   Although, program  start-up slipped to July
1984,  it  was decided to  keep Texas  in the FY1985  schedule
because of its  special characteristics.   The Texas  I/M program
is  the  only  I/M  program  implemented to  date  which  relies
exclusively  on  the   inspection  and  repair  of  tampered  and
otherwise  defective emission  control  system  components  rather
than  basing  the determination  of  the  need  for maintenance  on
emissions short tests.

                             Table  3

                    FY1985 I/M Audit  Schedule

                                                   Program
     Location                Pates                  Type*


Nevada                    10/15 - 10/19/84             C
New York                  12/10 - 12/14/84             D
Georgia                   1/22 -   1/25/85             C
Missouri                  3/04 -   3/08/85             C
Delaware                  3/07 -   3/08/85             B
North Carolina            3/18 -   3/22/85             C
Texas                     3/26 -   3/27/85             C
                          4/02 -   4/04/85
Oregon             .       4/15 -   4/19/85             B

*B -  centralized, government-run
 C =  decentralized
 D =  decentralized  with  computerized analyzers

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3.0  Audit Process for I/M Programs

     As embodied  in  the  NAAS,  the  I/M audit process  contains
four elements:

     1.    Audit preparation.

     2.    Audit visit.

     3.    Development of the audit report •.

     4.    Audit follow-up.

     The  preparation  for the  audit  allows  the  auditors  to
familiarize themselves with the  design  and  operations of  the
program under  review and  to  identify  those particular  aspects
of the program  which may need special  emphasis during the audit
visit.  Proper preparation will allow the auditors  to establish
priorities  for  various  audit  activities  in  order  to  make
efficient use  of  the  limited  time  available  during the  audit
visit.  It will also reduce  the State/local resources needed to
cooperate with  EPA  in the audit and the disruption  of  the I/M
program itself.

     The   auditors   assigned  to   perform   the   audit   must
collectively possess  as  much  knowledge  as  possible about  the
operations of  I/M  programs  in general  and about  the  specific
details  of  the  program  under  review.   The  goal  of  audit
preparation is  to  learn the  basic design of the I/M program, to
identify   as   much   as   possible    about    the   operating
characteristics  of  the program,   and  to  determine as  much as
possible  about  the  potential  strengths  and  weaknesses  of  the
program.  To  accomplish this, EPA auditors  assemble and review
documentation  on  the  program  to  be  audited  including  (1)
program   rules   and   regulations,   (2)   operating   manuals  or
procedures,   (3)   operating   reports,    (4)   documentation  of
previous   audits    or    investigations,   and    (5)   routine
correspondence  to  and from  program officials,  citizens,  and
other  interested parties.  To  facilitate audit preparation, the
I/M audit guidelines  include an I/M program questionnaire which
contains  questions  covering  the   relevant  aspects  of  an  I/M
program.

     The  audit  visit  is for  the  purpose  of  verifying  and
documenting whether  the program is being properly administered,
operated, and enforced  according to  established  laws, rules and
regulations,    and   procedural   requirements   in   .the   SIP.
Additionally,  the  audit  visit allows  a  better evaluation of
program  effectiveness  and  efficiency.   The  audit  visit  is
planned and  coordinated with  State/local  agencies   in  order to
minimize  the   level   of   intrusion  and  disruption  of  normal
program activities  and to make  the best use of both  EPA and

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     EPA staff  will  plan follow-up  activities  as necessary  to
encourage  and  assist  State  or   local  implementation  of  the
improvements  discussed  in  the  audit report.   In cases  where
deficiencies  must  be corrected,  follow-up audit visits may  be
necessary after corrective actions have been implemented.

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     Another   problem  area  in   some  programs   was  sticker
     accountability.   EPA  auditors  found  that  some programs
     have very thorough sticker accountability procedures while
     others do not.   In  order  to ensure the proper disposition
     of  stickers,  State/local  agencies  need  to  confirm that
     each  approval  sticker  has  a  matching  inspection  record
     showing   passing  results.   (This  same  confirmation   is
     needed in non-sticker programs  for approval  certificates,
     except  where  the   approval   certificates  and  official
     inspection reports are printed automatically by  machine.)
     This confirmation is accomplished in some current programs
     by  correlating  sticker  serial   numbers  to   inspection
     reports   and then  reviewing  inspection  records,  sticker
     records,  and sticker  supplies  during  audits.  In programs
     with automated data collection,  sticker serial numbers  can
     be  easily  recorded in the  inspection  report and  reviewed
     through  routine  data  analysis.   Because  of the potential
     for  data  loss  in  some  of  these  systems,  State/local
     agencies  need to be cautious about totally relying  on  the
     automatic records.

2.    Reported   failure  rates   -  EPA  auditors  found  reported
     failure   rates  as  high  as  35  percent and as  low  as  2
     percent.

     Reported   failure rates  were  consistently much  lower  than
     (less  that   half)   the  designed   failure   rates    in
     decentralized    programs.    (One     exception    was    a
     decentralized program with computerized analyzers.)  Also,
     there were  low  failure  rates  reported  in one  government
     run,  centralized  program.    The  contractor,  centralized
     programs   all  had reported  failure rates  in the  designed
     range.

     There are several reasons  for  the low  failure rates.   In a
     few  cases,   the   failure  rates  are  low  because  the  I/M
     cutpoints are too  lenient.  However, most of the  problems
     with   low   reported   failure    rates,    especially    in
     decentralized    programs,    are    caused    by    either
     pre-inspection  repairs,   cheating  by  inspectors,  or  some
     combination  of  these two factors.  EPA  believes  that  a
     strong inspection  station  surveillance  program is  needed
     to  ensure  proper  station performance.   This  surveillance
     program should include regular  station audits,  spot  checks
     with unmarked vehicles,  and the ability to  gauge and track
     station  performance through  data analyses.   Spot  checks
     with  unmarked  vehicles  set  to' fail  inspection, should be
     considered  an  indispensable part  of  the oversight function
     in  a  decentralized program,  particularly  a program  with
     manual analyzers.

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Analyzer quality  assurance -  EPA auditors  found quite  a
variation in  analyzer  quality assurance among  the  audited
programs.    In   the   centralized,   contractor   programs,
analyzer  quality  assurance  was  excellent.   However,  in
decentralized programs  with  manual analyzers  and in  some
centralized,  government  run  programs,   analyzer  quality
assurance was marginal.   These  problems  were  caused  by
several factors:

      a.    Lack of  a  comprehensive program of  preventive
            and corrective maintenance.

      b.    Lack of thorough  audit/surveillance  activities
            for inspection stations.

      c..   In some  cases,  existing  analyzers  are  rather
            old.

Data analyses -  EPA auditors  found that,  with  only  a few
exceptions,   I/M  programs  are  failing  to  effectively use
available  program  data  to  monitor  and  take  steps  to
improve  program  performance  and  performance of  individual
inspection stations. Of the programs  audited,  only  one had
routine  and timely data analyses which  included more than
failure  rates by  model   year  and  a  few  other  overall
statistics.

In  cases where   inspection  data  are collected manually,
there are a number of  problems which prevent, or at   least
limit,  the  collection  of  accurate data.   In  some  cases,
records  are  illegible  and  therefore  unusable.   A  more
serious  problem,   and  one   that  is  more  difficult  to
resolve, is that in many cases  inspectors  do not correctly
record  data.   EPA  auditors  found that  manually collected
data  records  often contain  easily identified  patterns  of
record  keeping (or other)  abuses.  In most cases, however,
the State/local agencies tend  to  categorize the problem as
inevitably  poor   record   keeping  practices  rather  than
attempting  to resolve them.   While  true  record  keeping
abuses  of  themselves may  not  be serious,  there is  no way
to analyze  the data to distinquish between record  keeping
errors  and  more  serious infractions,  such as falsification
of test  results in order to  improperly pass a  vehicle with
high  emissions  or  to   avoid  inspecting  a  vehicle  at all.
By  screening inspection  data,  agency field investigators
should  be  able  to  identify questionable  transactions  or
problem  stations.   Therefore,  EPA  considers  emphasis  on
collecting and analyzing valid data to be a high priority.

In cases where data are  collected automatically,  the data
are  generally  available  to   program  officials,  although
there  have   been  problems with data  loss  in  some  cases.
The problem in these cases tends  to be an  inability to use

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5.0  Conclusion

     EPA  believes  that  the  resolution  to  the  problems  in
operating  I/M programs  generally rests  with each  State/local
I/M program developing an overall  I/M  guality assurance  program
to ensure that problems  are  identified and resolved in a timely
manner.  Through such systems, program managers need to track:

     1.    The level of non-compliance among vehicle owners.

           This  is  particularly  important   in  non-registration
           enforcement   systems.   However,   even  registration
           enforcement is not necessarily exempt from problems.

     2.    The performance of  inspection stations to  make  sure
           that  vehicles  are  receiving fair,  equitable,   and
           accurate inspections.

           This   involves    inspection    station   audit   and
           surveillance   activities   as   well   as   tracking
           performance  through  data  analysis.   The  latter  is
           possible only if accurate data are collected.

     3.    The performance of the program itself.

           Program  data need  to be  summarized  and  analyzed to
           ensure that  cutpoints, failure  rates,  waiver rates,
           and  other  program  statistics are  within acceptable
           limits.

     4.    The guality of repairs.

           Quality  repairs .are  the  backbone  of  I/M.   Program
           data  need  to be  reviewed  to ensure that vehicles are
           not   being   improperly   or   incorrectly  repaired.
           Retest failure  rates  and  comparisons of before- and
           after-repair   emissions   levels   can   be   useful
           indicators to assess  the guality  of I/M repairs.

     Identifying  operating  problems  is  as  important first step
in  providing guality  I/M programs.    The results  of  completed
audits ' are  already- being used by State/local  agencies  and EPA
to  improve  I/M  programs.   EPA  believes  that  the  I/M  audit
system  and guidelines will  continue  to be a dynamic process for
achieving environmental  results.

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