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5 U.S. ENVIRONMENTAL PROTECTION AGENCY
* OFFICE OF INSPECTOR GENERAL
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Report Contributors:
Gabrielle Fekete
Jeffrey Harris
Denton Stafford
Olga Stein
Steve Weber
Abbreviations
COOP Continuity of Operations
EPA U.S. Environmental Protection Agency
FCD 1 Federal Continuity Directive 1
HSPD-20 Homeland Security Presidential Directive 20
OEM Office of Emergency Management
OIG Office of Inspector General
Cover photos:
From left: The Centers for Disease Control and Prevention-developed
Polymerase Chain Reaction diagnostic test to detect novel influenza virus;
image of the newly identified influenza virus; facemask to reduce transmission
of influenza virus (photos courtesy Centers for Disease Control and Prevention).
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I
5
U.S. Environmental Protection Agency
Office of Inspector General
At a Glance
10-P-0017
October 27, 2009
Catalyst for Improving the Environment
Why We Did This Review
The objective of this
evaluation was to determine
how well the U.S.
Environmental Protection
Agency (EPA) can accomplish
its mission essential functions
in the event of a pandemic
influenza or equivalent
national emergency that
necessitates Continuity of
Operations (COOP)
activation.
Background
Federal Continuity Directive 1
(FCD 1) requires EPA to
develop a continuity plan that
ensures its ability to
accomplish its mission
essential functions from an
alternative site with limited
staffing and without access to
resources available during
normal activities. EPA must
be prepared to continue to
function during an emergency
and to effectively resume
essential operations when they
are interrupted.
EPA Needs to Improve Continuity of
Operations Planning
What We Found
EPA has limited assurance that it can successfully maintain continuity of
operations and execute its mission essential functions during a significant national
event such as a pandemic influenza outbreak. EPA's COOP policy does not
clearly define authorities and responsibilities for continuity planning at all levels
of the Agency and has not been updated to reflect current national directives and
guidance. EPA lacks internal management controls, including guidance and
systematic oversight, to ensure that regional offices have developed continuity
plans that meet the requirements of FCD 1. Regional plans generally lack
consistency, particularly in the area of mission essential functions, and there was
no evidence that EPA Headquarters had reviewed, approved, or commented on the
regional plans, their designation, or lack of essential functions.
EPA's continuity training and exercises have not prepared the Agency to provide
essential services during a significant national event. EPA has not held and does
not require any all-employee continuity training. Also, EPA's continuity exercises
do not test EPA's ability to execute its mission essential functions following
COOP activation. Four out of six regions contacted and all but one program office
have not conducted internal exercises to test capabilities during a pandemic.
What We Recommend
EPA should establish a schedule to complete FCD 1 requirements, designate a
lead office for COOP planning, and identify Headquarters and regional
responsibilities and authorities. EPA should also develop consistent mission
essential functions and COOP plan preparation and training guidance for all
regions. Further, EPA Headquarters should review and approve all regional and
program office COOP plans. The Agency concurred with our recommendations.
For further information,
contact our Office of
Congressional, Public Affairs
and Management at
(202)566-2391.
To view the full report,
click on the following link:
www.epa.qov/oiq/reports/2010/
20091027-10-P-0017.pdf
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
OFFICE OF
INSPECTOR GENERAL
MEMORANDUM
SUBJECT:
FROM:
TO:
October 27, 2009
EPA Needs to Improve Continuity of Operations Planning
Report No. 10-P-0017
Wade T. Najjum
Assistant Inspector General
Office of Program Evaluation
Mathy Stanislaus
Assistant Administrator for Solid Waste and Emergency Response
This is our report on the subject evaluation conducted by the Office of Inspector General (OIG)
of the U.S. Environmental Protection Agency (EPA). This report contains findings that describe
the problems the OIG has identified and corrective actions the OIG recommends. This report
represents the opinion of the OIG and does not necessarily represent the final EPA position.
Final determinations on matters in this report will be made by EPA managers in accordance with
established resolution procedures.
The estimated cost of this report - calculated by multiplying the project's staff days by the
applicable daily full cost billing rates in effect at the time - is $519,022.
Action Required
In accordance with EPA Manual 2750, you are required to provide a written response to this
report within 90 calendar days. You should include a corrective actions plan for agreed upon
actions, including milestone dates. We have no objections to the further release of this report to
the public. This report will be available at http://www.epa.gov/oig.
If you or your staff have any questions regarding this report, please contact me at 202-566-0827;
or Jeffrey Harris, Director for Program Evaluation, Cross-Media Issues, at 202-566-0831 or
harris.ieffrev@epa.gov.
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EPA Needs to Improve 10-P-0017
Continuity of Operations Planning
Table of Contents
Chapters
1 Introduction 1
Purpose 1
Background 1
Noteworthy Achievements 2
Scope and Methodology 2
2 EPA's Continuity of Planning Operations Is Inconsistent 4
EPA's Continuity Policy Should Be More Definitive and Strengthened 4
Regional Continuity Plans Vary Significantly 5
Training and Exercises Are Insufficient 6
Conclusion 8
Recommendations 8
Agency Comments and OIG Evaluation 8
Status of Recommendations and Potential Monetary Benefits 10
Appendices
A Agency Comments on Draft Report 11
B Distribution 14
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Chapter 1
Introduction
Purpose
The overall objective of this evaluation was to determine how well the U.S.
Environmental Protection Agency (EPA) can accomplish its mission essential
functions in the event of a pandemic influenza or equivalent national emergency
that necessitates Continuity of Operations (COOP) activation. Specifically, we
sought to evaluate:
• The COOP responsibilities and authorities of EPA Headquarters and
regional offices,
• The consistency of mission essential functions across EPA and its regional
offices, and
• COOP exercises and training across EPA and its regional offices.
Background
Spurred in part by occasional warnings of potential terrorist threats in the
post-9/11 era, policymakers have intensified their focus on COOP issues.
COOP planning is a segment of Federal Government contingency planning linked
to continuity of government. Together, COOP and continuity of government are
designed to ensure survival of a constitutional form of government and the
continuity of essential federal functions.
Broadly, COOP planning refers to the internal effort of an organization, such as a
branch of government, department, or office, to assure that the capability exists to
continue essential operations in response to a comprehensive array of potential
operational interruptions. EPA must be prepared to continue to function during
all hazards, an emergency, or threat of an emergency, and to effectively resume
essential operations after they are interrupted. COOP plans provide EPA with the
capability to perform these essential functions for up to 30 days.
The Department of Homeland Security's Federal Continuity Directive 1 (FCD 1)
requires EPA to develop a continuity plan that ensures its ability to accomplish its
mission essential functions from an alternative site, with limited staffing and
without access to resources available during normal activities. A limited set of
government functions determined to be vital activities are defined as the agency's
"mission essential functions." These functions are used to identify supporting
tasks and resources that must be included in the agency's continuity planning
process.
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It is EPA's policy to have in place a comprehensive program (COOP) to ensure
continuity of its essential functions under all emergency circumstances. Under
Homeland Security Presidential Directive 20 (HSPD-20), EPA is required to
designate an Agency Continuity Coordinator charged with ensuring EPA's
continuity program is consistent with federal policies. The Office of Solid Waste
and Emergency Response's Office of Emergency Management (OEM) is
responsible for developing EPA's Continuity Plan.
EPA's Office of Homeland Security is responsible for coordinating the Agency's
intra-agency Pandemic Influenza preparedness planning. During a pandemic
outbreak, EPA performs a support role to the Departments of Homeland Security
and Health and Human Services in preparing and protecting the nation's drinking
water and wastewater critical infrastructure. EPA must be prepared for a
pandemic scenario where social distancing is a key coping strategy because
essential services and functions may be broader than 30-day COOP planning.
The Federal Government therefore recommends that government entities and the
private sector plan with the assumption that up to 40 percent of their staff may be
absent for periods of about 2 weeks at the height of a pandemic wave with lower
levels of staff absent for a few weeks on either side of the peak.
Noteworthy Achievements
The EPA Continuity Program has ensured the development of a COOP plan for
each regional office. The Agency recently developed its Primary Mission
Essential Function, as required by federal directives, and received approval from
the Assistant to the President for Homeland Security and Counterterrorism on
June 1, 2009. Regional continuity planners have developed a self-evaluation tool,
shared best practices, held annual meetings, and partnered with Headquarters
continuity planners through details to OEM.
Scope and Methodology
We conducted this performance evaluation in accordance with generally accepted
government auditing standards. Those standards require that we plan and perform
the evaluation to obtain sufficient, appropriate evidence to provide a reasonable
basis for our findings and conclusions based on our objectives. We believe that
the evidence obtained provides a reasonable basis for our findings and
conclusions based upon our objectives. We performed our evaluation from
September 2008 through August 2009.
This evaluation specifically focused on the management of EPA's COOP program
planning process. This includes federal requirements that dictate the roles and
responsibilities for EPA, and how specific offices have discharged those
responsibilities. Our field work included:
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• Interviews with officials in EPA's OEM and Office of Homeland Security
to determine Headquarters and regional COOP responsibilities and
authorities;
• Review of current Regional COOP Plans for Regions 1-10 and Research
Triangle Park, North Carolina, focusing on consistency of mission
essential functions;
• Review of Headquarters and selected regional COOP exercise "after
action" reports for Fiscal Years 2008-2009 to determine the extent of EPA
preparedness for COOP events; and
• Interviews with regional COOP planners on consistency of mission
essential functions, responsibility and authority, and exercises and
training.
Our review included examining applicable laws, regulations, and Agency
guidance. We also reviewed internal controls as relevant to our objectives.
This is our first examination of COOP planning and EPA's ability to
accomplish its mission essential functions; there have been no prior Office of
Inspector General (OIG) reviews in this area.
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Chapter 2
EPA's Continuity of Operations Planning
Is Inconsistent
EPA has limited assurance that it can successfully maintain continuity of
operations and execute its mission essential function during a significant national
event such as a pandemic influenza outbreak. Continuity planning is inconsistent
because EPA policy does not clearly define authority or Headquarters and
regional responsibilities to reflect current national directives and guidance. EPA
has not provided the regions with adequate guidance detailing the identification
and prioritization of essential functions, nor reviewed, approved, or commented
on regional plans or essential functions. Further, EPA lacks systematic oversight
to ensure that regions have developed continuity plans that adequately incorporate
FCD 1. EPA's COOP training and exercises are insufficient to prepare or assess
the Agency's ability to provide its essential services during a significant
emergency. As a result, EPA is not prepared to provide its essential services that
protect human health and the environment during a significant national event.
EPA's Continuity Policy Should Be More Definitive and Strengthened
EPA has not updated its continuity policy to reflect current national directives
(HSPD-20) and guidance (FCD 1.) EPA's current COOP policy, EPA Order
2030.1 A, "Continuity of Operations Policy," does not clearly define authorities
and responsibilities for COOP planning at all Agency levels.
HSPD-20 and FCD 1 require the heads of federal executive agencies to appoint a
senior accountable official at the Assistant Secretary level as the Continuity
Coordinator for the department or agency. EPA designated the Assistant
Administrator for Solid Waste and Emergency Response as the Agency's
Continuity Coordinator via a November 6, 2007, memorandum. However, this
memorandum did not define the responsibility and reach of authority for the
coordinator. OEM staff also said EPA has not outlined the coordinator's role.
EPA Order 2030.1 A, dated April 2005, predates HSPD-20 and FCD 1 and does
not meet all national requirements. Specifically, EPA Order 2030.1A does not
mention the role or responsibilities of the Agency Continuity Coordinator.
Instead, this order outlines the responsibilities of EPA's Emergency Coordinator.
The absence of the Agency Continuity Coordinator's role and responsibilities
contributes to the inconsistencies we found throughout EPA's COOP planning
efforts.
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EPA Order 2030.1A does not define the lead authority for continuity planning and
guidance development. Under current policy, EPA's Emergency Coordinator is
responsible for ensuring that the developed EPA COOP plan follows this order.
The Regional Administrators and Laboratory Directors are also responsible for
developing COOP plans in accordance with this order. The Emergency
Coordinator does not have direct approval authority over the Regional
Administrators' and Laboratory Directors' COOP plans.
Regional Continuity Plans Vary Significantly
While the EPA regions have actively participated in continuity planning since the
mid-1990s, mission essential functions and regional COOP plans vary
significantly from region to region. There was no evidence that EPA
Headquarters formally reviewed, approved, or commented on the regional plans,
their designation, or lack of essential functions. EPA lacks internal management
controls, including guidance and systematic oversight, to ensure regional offices
have developed continuity plans that adequately satisfy FCD 1 requirements.
The identification and prioritization of mission essential functions is a prerequisite
for COOP planning, as they establish the parameters that guide COOP planning.
For example, FCD 1 directs all federal agencies to identify alternative facilities,
staff, and resources necessary to support continuation of these functions. Proper
identification of mission essential functions is vital to ensure EPA has the ability
to deliver its mission essential functions and services uninterrupted during a range
of potential emergencies. The COOP plans we reviewed for identified mission
essential functions varied in number and scope. Regions generally did not
prioritize or establish the time sensitivity of the functions they had identified.
Also, the apparent importance of the functions was not consistent. For example, a
number of mission essential functions were of clear importance, such as:
• "Ensure the continued and uninterrupted command, control, and
leadership of the EPA."
• "Emergency Response program, time critical actions EPA needs to take."
• "Communicate and coordinate with state agencies and local
governments."
Other identified functions appeared of questionable importance or overly vague:
• "Oversee the ethics program for the Agency."
• "Protect the office's workforce in accordance with guidance issued by
EPA."
• "Support current ongoing EPA activities that cannot or should not be
disrupted..."
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EPA Headquarters last issued guidance for COOP planning in 2005. This
guidance outlined basic minimum requirements for continuity plans, training, and
coordinating personnel. However, unlike EPA Order 2030.1 A, FCD 1 does
require EPA Headquarters to review and approve Agency mission essential
functions that are a necessary element to COOP plan development. We found no
evidence of the EPA Continuity Coordinator's review of regional plans. OEM
receives courtesy copies of the plans but does not formally review them. This
absence of management controls has resulted in inconsistent continuity planning
nationally, and may negatively impact EPA's readiness to respond to an incident
of national significance.
Our review of COOP plans developed or being used by the regions during Fiscal
Year 2009 showed that many regional offices had not incorporated all of the
FCD 1 requirements. EPA regions were still citing Federal Preparedness
Circular 65, which was superseded by FCD 1 in February 2008. Issues such as
vital records, devolution (capability to transfer statutory authority and
responsibility), and reconstitution (resume normal agency operations) had not
been fully addressed by many regions. To address the issue of devolution, the
regions recently formed a work group.
Although regional COOP plans generally adhered to the FCD 1 criteria, we found
four elements that needed improvement in more than one region:
• Identification of Essential Functions
• Vital Record Management
• Devolution of Control and Direction
• Reconstitution
Our results show that not all regions have differentiated their essential functions
from their normal business operations, and not all regions have determined how
they will address vital record issues, potential devolution issues, or reconstitution
of normal activities.
Training and Exercises Are Insufficient
EPA's continuity training and exercises do not sufficiently prepare or assess the
Agency's ability to provide its essential services during a significant emergency.
EPA's training scenarios primarily test equipment, communication systems, and
access to records. Four out of six regions contacted and all but one program
office have not conducted internal exercises for a pandemic. Feedback and
lessons learned in "after action" reports indicate the need for more realistic
exercises. However, EPA lacks a consistent process for addressing the
recommendations or gaps identified from these lessons learned.
EPA training scenarios lack a comprehensive focus. We found that all regions
reviewed activated a telephone tree or similar emergency system, deployed
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essential personnel to site, tested information technology and communication
systems, and reviewed vital records. Few training scenarios required a complete
deployment of resources and used minimal staff at the alternative site. Exercises
held at designated alternative sites focused primarily on discussion of possible
scenarios and communication issues rather than operation of essential functions.
For example, Regions 1, 2, and 9 all conducted "tabletop" exercises1 at their
alternative sites but did not require a complete deployment of resources using
designated staff.
We found that only Headquarters' Office of Prevention, Pesticides, and Toxic
Substances and Region 6 have conducted internal exercises for the pandemic
influenza. Other regions have added a Pandemic Influenza Annex to their COOP
plans but have not conducted exercises that would prepare for this scenario. The
pandemic scenario includes unique requirements, such as a telework component,
where staff would have to work for many contiguous days in a social distancing
situation.
Regions vary on the extent and frequency of training for all employees. We asked
several of the regional COOP planners if they provided continuity training for all
of their employees. One replied that regional staff could find COOP information
on the regional Intranet site. Another said he relies on the divisional COOP
planners to provide this. EPA Headquarters has not held and does not require any
all-employee continuity training.
EPA does not have a consistent process for addressing the recommendations or
gaps identified from lessons learned during the exercises. The after action reports
we reviewed all contain different formats and schedules for completion.
Generally, each report contains sections where the regional COOP manager
identifies action items and deadlines to complete these items, and designates the
staff/group responsible for the item. Each regional COOP planner is responsible
for his or her own plan after action reports and deadlines.
After action reports indicated the need for more realistic exercises; the reports
often described gaps or necessities in these areas. One comment provided by staff
was, "The MTSD [Management and Technical Services Division] will work to
ensure essential staff know their role/responsibilities." Another report
recommended that the "Notification program for all EPA HQ employees in the
National Capital Region must be exercised during a COOP deployment." Staff
offered recommendations to improve the design of the exercise, including:
"Recommend more regular and realistic exercises; need to grow exercise into an
actual event simulation" and "Recommend increasing the interaction with other
AA [Assistant Administrator]-ships and external partners."
1 A tabletop exercise is the analysis of a simulated emergency situation in an informal, stress-free environment.
There is minimal attempt at simulation in a tabletop exercise. Equipment is not used, resources are not deployed,
and time pressures are not introduced. This is the simplest type of exercise to conduct in terms of planning,
preparation, and coordination.
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Conclusion
EPA has limited assurance that it can successfully maintain continuity of
operations and execute its mission essential function during a significant national
event such as a pandemic influenza outbreak. EPA's current policy does not
clearly define authority and EPA Headquarters and regional responsibilities. This
has created inconsistencies in continuity planning and training, and varying
mission essential functions and continuity plans by the regions. As a result, there
is no assurance that EPA will be able to provide its essential services to protect
human health and the environment during a national emergency.
Recommendations
We recommend that the Assistant Administrator for Solid Waste and Emergency
Response:
2-1 Establish a schedule for the completion of the requirements in FCD 1.
2-2 Establish Headquarters and regional COOP responsibilities and
authorities, including designating a lead office for COOP planning.
2-3 Develop consistent guidance and procedures for preparing regional COOP
plans.
2-4 Develop consistent mission essential functions and priorities for all
regions to include in their COOP plans.
2-5 Develop training guidance that incorporates realistic scenarios that prepare
personnel to perform mission essential functions during a COOP
activation (i.e., from an alternate location with limited staff).
2-6 Review and approve COOP plans, priorities, training, and exercises to
ensure that EPA's regional and program offices (a) systematically identify
their mission essential functions and personnel, and (b) are prepared to
respond to an all-hazards event.
Agency Comments and OIG Evaluation
In written comments on a draft of this report, the Assistant Administrator for
Solid Waste and Emergency Response and the Acting Assistant Administrator for
Homeland Security generally agreed with our findings regarding consistency of
continuity planning, EPA's continuity policy, regional continuity plans, and
training and exercises. They also included a table of the Office of Solid Waste
and Emergency Response's planned completion dates for our recommendations.
These actions are consistent with the intent of our recommendations. However,
the Agency officials did not concur with the OIG's overall conclusion that EPA
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has "no assurance" that it can successfully maintain continuity of operations and
execute its mission essential functions during a significant national event such as
a pandemic influenza outbreak. We modified the report language in light of the
Headquarters' ongoing actions in response to FCD 1 and the various exercises
conducted in several regions. The Agency's written response is in Appendix A.
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Status of Recommendations and
Potential Monetary Benefits
RECOMMENDATIONS
POTENTIAL MONETARY
BENEFITS (in SOOOs)
Rec.
No.
2-1
2-2
2-3
2-4
2-5
Page
No.
8
8
8
8
8
Subject Status1
Establish a schedule for the completion of the 0
requirements in FCD 1.
Establish Headquarters and regional COOP 0
responsibilities and authorities, including
designating a lead office for COOP planning.
Develop consistent guidance and procedures for 0
preparing regional COOP plans.
Develop consistent mission essential functions and 0
priorities for all regions to include in their COOP
plans.
Develop training guidance that incorporates 0
realistic scenarios that prepare personnel to
perform mission essential functions during a COOP
activation (i.e., from an alternate location with
limited staff).
Action Official
Assistant Administrator
for Solid Waste and
Emergency Response
Assistant Administrator
for Solid Waste and
Emergency Response
Assistant Administrator
for Solid Waste and
Emergency Response
Assistant Administrator
for Solid Waste and
Emergency Response
Assistant Administrator
for Solid Waste and
Emergency Response
Planned
Completion Claimed Agreed To
Date Amount Amount
11/15/2009
6/30/2010
10/30/2010
10/30/2010
2/15/2011
2-6 8 Review and approve COOP plans, priorities,
training, and exercises to ensure that EPA's
regional and program offices (a) systematically
identify their mission essential functions and
personnel, and (b) are prepared to respond to an
all-hazards event.
Assistant Administrator
for Solid Waste and
Emergency Response
0 = recommendation is open with agreed-to corrective actions pending
C = recommendation is closed with all agreed-to actions completed
U = recommendation is undecided with resolution efforts in progress
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Appendix A
Agency Comments on Draft Report
MEMORANDUM
SUBJECT: Response to the OIG Draft Evaluation Report "EPA Needs to Improve
Continuity of Operations Planning," Project No. OPE-08-0024
FROM: Mathy Stanislaus
Assistant Administrator
Office of Solid Waste and Emergency Response
Juan Reyes
Acting Assistant Administrator
Office of Homeland Security
TO: Jeffrey K. Harris, PhD
Director for Program Evaluation, Cross Media Issues
Office of Inspector General
Thank you for the opportunity to review and comment on the subject OIG draft report.
The report addresses EPA's continuity policy, Regional continuity plans, training and exercises
and provides a list of recommendations for improvement. We would also like to thank you for
incorporating some of the comments that we had requested in our June 25, 2009, response to the
discussion draft and for describing noteworthy achievements at Headquarters and in the Regions.
As we stated in our June response, the OIG performed the evaluation in the midst of
OSWER's efforts to update the EPA Headquarters Continuity Plan, the Pandemic Influenza
Annex, and the Devolution Annex. We are also in the process of updating the existing EPA
Order that incorporates the requirements of the Department of Homeland Security's Federal
Continuity Directives 1 and 2. We generally agree with the findings regarding consistency of
continuity planning, EPA's continuity policy, Regional continuity plans, and training and
exercises. However, many of the OIG's concerns will be addressed upon completion of the
updated Continuity of Operations Plan and a revised EPA Order.
We do, however, take exception that these findings lead to a conclusion that EPA has "no
assurance" that it can successfully maintain continuity of operations and execute its mission
essential functions during a significant national event such as a pandemic influenza outbreak.
Recognizing that our program does need improvement, we have made extensive progress
developing our COOP plans and exercising key capabilities of essential personnel. While our
exercises have shown areas in need of improvement, we have been evaluated by FEMA, GAO
and other independent subject-matter assessors, and these appraisals have generally received
acceptable scores for key Federal requirements. Based on your findings and our program
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knowledge, we assess that your conclusion of "no assurance" is imprecise because it does not
accurately reflect the status of our program, and is not consistent with previous outside
evaluations. We ask that the statement be changed to "limited assurance" to more accurately
reflect the state of our COOP Program.
As requested, we have included the table of proposed recommendations and OSWER's
planned completion dates. We look forward to coordinating with OIG, other AAships, and the
Regional offices to continue to improve our continuity program. If you have any questions,
please contact Deborah Dietrich, Director of the Office of Emergency Management, at
202-564-6743.
Attachment
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OIG Recommendations to Improve EPA's Continuity Program
Recommendation
Subject
OSWER Planned
Completion Date
2-1
Establish a schedule for completion of the
requirements in FCD 1.
11/15/2009
2-2
Establish Headquarters and Regional
COOP responsibilities and authorities,
including designating a lead office for
COOP planning.
6/30/2010
2-1
Develop consistent guidance and
procedures for preparing Regional COOP
plans.
10/30/2010
2-4
Develop consistent mission essential
functions and priorities for all Regions to
include in their COOP plans.
10/30/2010
2-5
Develop training guidance that
incorporates realistic scenarios that prepare
personnel to perform mission essential
functions during a COOP activation (i.e.,
from an alternate location with limited
staff).
2/15/2011
2-6
Review and approve COOP plans,
priorities, training, and exercises to ensure
that EPA's Regional and program offices
(a) systematically identify their mission
essential functions and personnel, and (b)
are prepared to respond to an all-hazards
event.
Annual review
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Appendix B
Distribution
Office of the Administrator
Assistant Administrator for Solid Waste and Emergency Response
Acting Assistant Administrator for Homeland Security
Director, Office of Emergency Management, Office of Solid Waste and Emergency Response
General Counsel
Agency Follow-up Official (the CFO)
Agency Follow-up Coordinator
Associate Administrator for Congressional and Intergovernmental Relations
Associate Administrator for Public Affairs
Audit Follow-up Coordinator, Office of Solid Waste and Emergency Response
Acting Inspector General
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