^tDsrx * g% * \Wi V PR0^° U.S. ENVIRONMENTAL PROTECTION AGENCY OFFICE OF INSPECTOR GENERAL Science and Research Follow-Up Review: EPA Updated Information for Indoor Mold Research Tools Report No. 16-P-0308 September 8, 2018 ------- Report Contributors: Benjamin Beeson Hilda Canes-Garduno Dwayne Crawford Eric Lewis Abbreviations EPA U.S. Environmental Protection Agency ERMI Environmental Relative Moldiness Index MATS Management Audit Tracking System MSQPCR Mold Specific Quantitative Polymerase Chain Reaction OIG Office of Inspector General ORD Office of Research and Development Cover photos: Mold growing on the backside of wallpaper (left), and on the surface of a unit ventilator (right). (EPA photos) Are you aware of fraud, waste or abuse in an EPA program? EPA Inspector General Hotline 1200 Pennsylvania Avenue, NW (2431T) Washington, DC 20460 (888) 546-8740 (202) 566-2599 (fax) OIG Hotline@epa.gov Learn more about our OIG Hotline. EPA Office of Inspector General 1200 Pennsylvania Avenue, NW (2410T) Washington, DC 20460 (202) 566-2391 www.epa.gov/oiq Subscribe to our Email Updates Follow us on Twitter @EPAoig Send us your Project Suggestions ------- ^tDsr-% • B \ U.S. Environmental Protection Agency Office of Inspector General At a Glance 16-P-0308 September 8, 2016 Why We Did This Review We assessed the U.S. Environmental Protection Agency's (EPA's) actions to address recommendations in Office of Inspector General (OIG) Report No. 13-P-0356. Public May Be Making Indoor Mold Cleanup Decisions Based on EPA Tool Developed Only for Research Applications, issued August 22, 2013. The Assistant Administrator for the Office of Research and Development was the action official responsible for ensuring completion of the corrective actions we reviewed. This report addresses the following EPA core value: • Science, Transparency, and Rule of Law. Follow-Up Review: EPA Updated Information for indoor Moid Research Toois What We Found Corrective actions taken by the EPA should help ensure that the public has correct information about EPA- approved technology and tools for evaluating indoor mold. In 2013, we reported that some licensees were inappropriately marketing the EPA-patented Mold Specific Quantitative Polymerase Chain Reaction technology and the agency- developed Environmental Relative Moldiness Index tool. The OIG noted that some licensee advertising could mislead the public into thinking that the EPA had endorsed these research tools for evaluating indoor mold for public use, even though the EPA readily acknowledged that these tools were for research applications only and had not been validated for public use. The OIG's 2013 report contained three recommendations to address these concerns. Recommendations 1 and 3 remained open with corrective actions pending, and Recommendation 2 was closed upon issuance of the final report. For the two open recommendations, the EPA completed agreed-upon corrective actions. The EPA reviewed websites of active licensees to look for language that suggests EPA endorsement, and finalized the agency's fact sheet on indoor mold to include discussion on the tools' limitations. These actions resulted in updated information, and agency reviews of licensee websites helped ensure that information about the agency's tools is correct. We make no further recommendations. Send all inquiries to our public affairs office at (202) 566-2391 or visit www.epa.gov/oiq. Listing of OIG reports. ------- UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D.C. 20460 THE INSPECTOR GENERAL September 8, 2016 MEMORANDUM SUBJECT: Follow-Up Review: EPA Updated Information for Indoor Mold Research Tools Report No. 16-P-03C FROM: Arthur A. Elkins Jr. TO: Thomas Burke, Deputy Assistant Administrator and EPA Science Advisor Office of Research and Development This is our report on the subject review conducted by the Office of Inspector General (OIG) of the U.S. Environmental Protection Agency (EPA). The project number for this review was OPE-FY16-0020. EPA officials reviewed our draft findings and had no comments. Because this report contains no recommendations, you are not required to respond to this report. However, if you submit a response, it will be posted on the OIG's public website, along with our memorandum commenting on your response. Your response should be provided as an Adobe PDF file that complies with the accessibility requirements of Section 508 of the Rehabilitation Act of 1973, as amended. The final response should not contain data that you do not want to be released to the public; if your response contains such data, you should identify the data for redaction or removal, along with corresponding justification. We will post this report to our website at www.epa.gov/oig. ------- Follow-Up Review: EPA Updated Information for Indoor Mold Research Tools 16-P-0308 Table of C Purpose 1 Background 1 Responsible Office 1 Scope and Methodology 1 Results of Review 2 Conclusion 3 Appendix A Distribution 4 ------- Purpose We conducted this review to follow up on the status of corrective actions taken by the Office of Research and Development (ORD) of the U.S. Environmental Protection Agency (EPA) in response to recommendations in Office of Inspector General (OIG) Report No. 13-P-0356. Public May Be Making Indoor Mold Cleanup Decisions Based on EPA Tool Developed Only for Research Applications, issued August 22, 2013. Background The 2013 OIG report found that some licensees' advertising had the potential to mislead the public into thinking that the mold specific quantitative polymerase chain reaction (MSQPCR) and Environmental Relative Moldiness Index (ERMI) research tools were EPA-approved methods for evaluating indoor mold. The prior report was conducted as a result of a hotline complaint that alleged that firms were using the EPA-developed tool even though the EPA had not validated it for public use. The EPA readily acknowledged that it had not validated the MSQPCR or the ERMI, since those research tools were not intended for public use. That 2013 OIG report contained three recommendations to the Assistant Administrator for ORD: 2013 OIG Recommendations 1. Periodically review licensee advertising to determine whether licensees have violated the terms of their agreements by implying the EPA's endorsement of MSQPCR and take appropriate action based on the results of this review. 2. Remove or clarify statements on the EPA's website that imply or suggest the EPA validated or endorsed MSQPCR for public use. 3. Finalize the fact sheet on indoor mold, MSQPCR and ERMI to include discussion on the limitations of these tools and make it available to the public, including posting the fact sheet on the EPA's website. Source: OIG Report No. 13-P-0356. Responsible Office ORD was responsible for completing the recommendations in the OIG's 2013 report. Scope and Methodology We performed our follow-up review from April through July 2016. We did not follow up on Recommendation 2 because it was closed when the OIG issued the 2013 report. For Recommendations 1 and 3, we verified whether information 16-P-0308 1 ------- from the EPA's Management Audit Tracking System (MATS) matched documentation provided by ORD as corrective actions taken. We conducted this performance audit in accordance with generally accepted government auditing standards. Those standards require that we plan and perform the audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives. We believe that the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objectives. Results of Review The EPA reported completed corrective actions for Recommendations 1 and 3 from the 2013 OIG report. Our review verified that information entered into MATS matched the documentation provided by ORD for the completed corrective actions taken, as shown in Table 1. Table 1: OIG review of EPA corrective actions 2013 OIG recommendations EPA corrective action 1. Periodically review licensee advertising to determine whether licensees have violated the terms of their agreements by implying the EPA's endorsement of MSQPCR and take appropriate action based on the results of this review. ORD completed two annual reviews of websites for all active MSQPCR licensees to look for language implying EPA endorsement or validation, and found no problems. OIG review Reviews for 2014 and 2015 addressed the recommendation to ensure there was no EPA-implied endorsement or validation of MSQPCR technology. We verified that MATS data correctly reflects the status of corrective actions taken. 3. Finalize the fact sheet on indoor mold, MSQPCR and ERMI to include discussion on the limitations of these tools and make it available to the public, including posting the fact sheet on the EPA's website. EPA corrective action ORD finalized the fact sheet on indoor mold, MSQPCR and ERMI, to include discussion on the limitations of these tools, and posted that information to the public on the EPA's website. OIG review The finalized fact sheets and index on the EPA website addressed the recommendation because they include discussion on the limitations of the tools and are available to the public. We verified that MATS data correctly reflect the status of corrective actions taken. Sources: The EPA's MATS, OIG Report No. 13-P-0356, discussions with agency personnel, and OIG analysis. During our review, ORD officials inquired about the frequency for conducting periodic reviews of licensee websites. While we believe that these reviews are instrumental to ensuring the validity of licensee advertising, we also believe the frequency of these reviews should be left to the discretion of the agency. 16-P-0308 2 ------- Conclusion The corrective actions taken by the EPA should help prevent the public from being misled into thinking that licensee marketing of EPA-approved technology and tools for evaluating indoor mold suggests endorsement or validation by the EPA. The corrective actions satisfy Recommendations 1 and 3 of the OIG's 2013 report. Consequently, we make no additional recommendations. 16-P-0308 3 ------- Appendix A Distribution Office of the Administrator Assistant Administrator for Research and Development Agency Follow-Up Official (the CFO) Agency Follow-Up Coordinator General Counsel Associate Administrator for Congressional and Intergovernmental Relations Associate Administrator for Public Affairs Deputy Assistant Administrator and EPA Science Advisor, Office of Research and Development Deputy Assistant Administrator for Science, Office of Research and Development Principal Deputy Assistant Administrator for Management, Office of Research and Development Associate Assistant Administrator, Office of Research and Development Audit Follow-Up Coordinator, Office of Research and Development 16-P-0308 4 ------- |