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U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF INSPECTOR GENERAL
Science and Research
EPA Has Adequate Controls to
Manage Advice From Science
and Research Federal Advisory
Committees, but Transparency
Could Be Improved
Report No. 17-P-0124
March 13, 2017
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Report Contributors:
Patrick Gilbride
Erin Barnes-Weaver
Todd Goldman
James Kohler
Kalpana Ramakrishnan
Abbreviations
BOSC
Board of Scientific Counselors
CASAC
Clean Air Scientific Advisory Committee
CHPAC
Children's Health Protection Advisory Committee
CMO
Committee Management Officer
CSAC
Chemical Safety Advisory Committee
DFO
Designated Federal Officer
ELAB
Environmental Laboratory Advisory Board
EPA
U.S. Environmental Protection Agency
FAC
Federal Advisory Committee
FACA
Federal Advisory Committee Act
FIFRA SAP
Federal Insecticide, Fungicide, and Rodenticide Act Scientific Advisory Panel
FY
Fiscal Year
GAO
U.S. Government Accountability Office
GSA
U.S. General Services Administration
HSRB
Human Studies Review Board
OIG
Office of Inspector General
OMB
Office of Management and Budget
OROM
Office of Resources, Operations and Management
SAB
Science Advisory Board
S&R
Science and Research
U.S.C.
United States Code
Cover photo: Members of the Science Advisory Board, an EPA federal advisory committee,
attend a meeting. (EPA photo)
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
THE INSPECTOR GENERAL
March 13, 2017
MEMORANDUM
SUBJECT: EPA Has Adequate Controls to Manage Advice From Science and Research
Federal Advisory Committees, but Transparency Could Be Improved
Report No. 17-P-0124
FROM: Arthur A. Elkins Jr.
TO:
Donna Vizian, Acting Assistant Administrator
Office of Administration and Resources Management
This is our report on the subject evaluation conducted by the Office of Inspector General (OIG) of the
U.S. Environmental Protection Agency (EPA). The project number for this evaluation was
OPE-FY16-0024. This report contains findings 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 audit resolution procedures.
Action Required
In accordance with EPA Manual 2750, your office provided planned corrective actions in response to
our recommendations. All recommendations are considered resolved. You are not required to provide a
written response to this final report because you provided agreed-to corrective actions and planned
completion dates for the report recommendations. The OIG may make periodic inquiries on your
progress in implementing these corrective actions. Please update the EPA's Management Audit
Tracking System as you complete planned corrective actions. Should you choose to provide a final
response, we will post your response on the OIG's public website, along with our memorandum
commenting on your response. You should provide your response 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.
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EPA Has Adequate Controls to Manage Advice
From Science and Research Federal Advisory
Committees, but Transparency Could Be Improved
17-P-0124
Table of C
Reasons for Review 1
Background 1
The Federal Advisory Committee Act 1
EPA's S&R FACs 1
EPA's Management of FACs 2
FAC Products and Public Access 3
Federal Internal Control Standards 4
Responsible Offices 5
Scope and Methodology 5
Limitations 6
Results of Review 6
EPA's System of Controls Are Effective 7
(1) EPA Addressed All Sample Products 7
(2) EPA Tracked All Recommendations 9
(3) FAC Chairs Satisfied but Identified Areas for Improvement 9
Conclusion 10
Recommendations 11
Agency Response and OIG Evaluation 11
Status of Recommendations and Potential Monetary Benefits 12
Appendices
A Agency Response to Draft Report 13
B Distribution 16
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Reasons for Review
We conducted this evaluation to determine what system(s) of controls the U.S.
Environmental Protection Agency (EPA) has in place to engage with and manage
the recommendations and advice from its science and research (S&R) federal
advisory committees (FACs) and whether this system of controls is effective.
Background
The Federal Advisory Committee Act
Congress passed the Federal Advisory
Committee Act (FACA), 5 U.S.C.,
Appendix 2, in 1972 (as amended), to create
an orderly procedure by which federal
agencies may seek collective advice from
FACs. The act ensures that FACs are
governed via uniform standards and
procedures. Further, according to the EPA,
FACA establishes procedures for the
management of FACs, ensures FAC
decision-making is transparent, and ensures
representation on FACs is balanced. FACA states that FACs should be only
advisory in nature and that all matters should ultimately be determined in
accordance with the law by the official, agency or officer involved. FACA also
requires that agencies maintain systematic information on operations of FACs
within their jurisdiction.
The U.S. General Services Administration (GSA) is responsible for overseeing
FACA, as well as for developing regulations and guidance to govern the
management and consistent use of FACs across the government. Agencies should
establish guidelines and management controls for FACs. FACA stipulates that
agencies must submit an annual report detailing the FACs' activities for the
previous fiscal year. With this information, the GSA has created and maintains a
FACA Database1 as a repository of data about the FACs' current fiscal year
events and performance. This database includes a feature that tracks the number
of FAC recommendations and whether they have been implemented.
EPA's S&R FACs
FACs are an important tool within the EPA for building consensus and providing
input and recommendations from the agency's diverse customers, partners and
stakeholders. As of February 2016, the EPA managed 22 FACs that assisted the
1 To access the GSA FACA Database and FAC recommendations by federal agency, see http://www.facadatabase.
gov/default.aspx.
A FAC is any committee, board,
commission, council, conference,
panel, task force or other similar
group (including any subcommittee
or other subgroup thereof) that is
established or utilized by the federal
government to obtain advice or
recommendations and that is not
composed solely of full-time or
permanent part-time federal officers
or employees.
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agency in carrying out its mission to protect human health and the environment.
The agency provides financial and administrative support for these FACs. Each
FAC charter contains key information, including the committee's objectives and
scope of activity. From the most recent charters available, we identified eight
FACs that provide S&R advice and recommendations to the EPA. Table 1 lists
these FACs, along with their managing agency program offices and estimated
annual costs. Based on fiscal year (FY) 2015 data, the total estimated annual
operating costs for the eight S&R FACs is more than $8 million.
Table 1: S&R FACs at the EPA
FAC name
Managing program office
Annual cost
(estimated)
1
Board of Scientific
Counselors (BOSC)
Office of Research and
Development
$628,000
2
Chemical Safety Advisory
Committee (CSAC)
Office of Chemical Safety and
Pollution Prevention
434,000
3
Children's Health Protection
Advisory Committee
(CHPAC)
Office of the Administrator's
Office of Children's Health
Protection
395,000
4
Clean Air Scientific Advisory
Committee (CASAC)
Office of the Administrator's
Science Advisory Board Office
1,500,000
5
Environmental Laboratory
Advisory Board (ELAB)
Office of Research and
Development
45,000
6
Federal Insecticide,
Fungicide, and Rodenticide
Act Scientific Advisory Panel
(FIFRA SAP)
Office of Chemical Safety and
Pollution Prevention
1,940,000
7
Human Studies Review
Board (HSRB)
Office of Research and
Development's Office of the
Science Advisor
150,000
8
Science Advisory Board
(SAB)
Office of the Administrator's
Science Advisory Board Office
3,000,000
Annual S&R FAC costs (estimated)
$8,092,000
Source: Office of Inspector General (OIG) summary of information in individual FAC charters.
EPA's Management of FACs
Within the EPA, the Office of Resources, Operations and Management (OROM)
provides oversight for the establishment and operation of the agency's FACs. In
2012, OROM developed the Federal Advisory Committee Handbook (commonly
referred to as the FAC A Handbook), an agencywide guidance document that
outlines processes for managing FACs. The EPA's policies and procedures
relating to FACs are codified in the agency's FAC A Handbook.
The FAC A Handbook identifies the EPA staff responsible for managing and
addressing the recommendations of the agency's FACs:
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• Designated Federal Officers (DFOs) work with the FAC chairs, FAC
members and appropriate staff as the primary managers and record keepers of
the FACs. DFOs are also responsible for working closely with the EPA
program officials to obtain timely responses to and track responses to FAC
recomm endati ons.
• The Committee Management Officer (CMO), who is appointed by the Director
of OROM, serves as a resource for DFOs and ensures proper record keeping
for FACs.
• The relevant program office supports the DFO as required, including
providing charge questions to the FAC and determining when the FAC is no
longer needed.
• Senior management2 in the relevant program offices is responsible for
preparing a "prompt response to advisory committee recommendations
relating to EPA's proposals for action, or reasons for inaction, or important
developments and significant actions, etc."
FAC Products and Public Access
All FAC meetings are open to the public unless otherwise determined in advance
by the EPA Administrator. FAC meetings can result in various products (Table 2).
The S&RFACs in our review created 84 products from FY 2013 through
FY 2015.
Table 2: FAC products and definitions
FAC products
EPA FACA Handbook definitions
Meeting Minutes
Reports
Reports comprising the meeting minutes recorded, the
recommendations issued, the decisions made, and the ideas
expressed.
Consultations
Early, low-cost endeavors to obtain individual member views on
issues for which the EPA has not yet developed a plan of action.
No intent or expectation that a consultation will result in a report
or specific recommendation.
Commentaries
Thoughts from committee members that the committee believes
are important enough to be conveyed to the Administrator and
the public. Often presented in the form of a letter.
Peer Review
Reports
Independent reviews of near-final EPA work products that are the
result of several committee meetings where the EPA presented
information, the public commented, and the committee discussed
the presented issues.
2 Senior managers at the EPA include program office Assistant Administrators, Regional Administrators and
Associate Administrators (or equivalents).
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FAC products
EPA FACA Handbook definitions
Advisories
Documents that are similar to Peer Review Reports but that are
developed while the EPA still has flexibility regarding its plans to
close out the discussed project. Can also be a "midcourse"
review that provides suggestions on how to proceed with a
preexisting project.
Recommendation
Letters
Documents that relate to whatever segment of a multi-segment
project the committee is working on. Usually presented in the
form of a letter to the Administrator.
Committee
Reports
Formal summaries of the findings of the committee. Includes
advice the committee gives the agency and the findings or
decisions made during committee meetings.
Source: OIG summary of the EPA's 2012 FACA Handbook.
The FACA Handbook recommends that documents3 provided to or prepared by
each FAC should be placed in the official committee file. The FACA Handbook
requires that this file be available for public inspection and copying.
In addition to the FACA Handbook, DFOs can also consult the agency's Peer
Review Handbook,4 which includes a section on peer review by FACs. The EPA
utilizes the peer review process to "identify any technical problems or unresolved
issues in a preliminary (or draft) work product through the use of independent
experts." The Peer Review Handbook notes that FACA requirements for advanced
notification of committee meetings and opportunities for public participation add
to the time required to complete the review but enhance the transparency of the
peer review process.
According to the EPA's Scientific Integrity Policy, in order to ensure
transparency, the agency needs to allow the "free flow of scientific information."
The Scientific Integrity Policy is the framework to ensure integrity throughout the
agency, including FACs, and states that the EPA needs to promote and provide
access to the public by making scientific information available online.
Federal Internal Control Standards
In addition to congressional, GSA and EPA mandates that specifically pertain to
FACs, the agency must also comply with federal internal control standards as
applicable, including the following standards:
• U.S. Government Accountability Office (GAO), Standards for Internal
Control in the Federal Government, GAO-14-704G, September 2014:
These standards define internal control as "a process effected by an
entity's oversight body, management, and other personnel that provides
3 EPA documents that are exempted from public review under FACA, such as privileged or confidential documents,
shall be placed in a separate file.
4 EPA, Science and Technology Policy Council Peer Review Handbook, 4th edition, October 2015.
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reasonable assurance that the objectives of an entity will be achieved."
Internal control comprises the plans, methods, policies and procedures
used to fulfill the goals and objectives of the entity. GAO's standards
require documentation of agency activities, which provides a means to
retain organizational knowledge and mitigate the risk of having that
knowledge limited to a few personnel, as well as a means to communicate
that knowledge as needed to external parties. The standards also require
that the EPA promptly resolve the findings of audits and other reviews.
• Office of Management and Budget (OMB) Circular No. A-123,
Management's Responsibility for Enterprise Risk Management and
Internal Control, July 15, 2016: This document states that the agency's
management is responsible for developing and maintaining effective
internal control.
Responsible Offices
The Office of Resources, Operations and Management, within the Office of
Administration and Resources Management, has primary responsibility for
subjects covered in this review.
Scope and Methodology
We conducted our work from June 2016 through February 2017. 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.
We met with DFOs and key OROM staff to identify the system of controls the
EPA has in place to engage with and manage FACs. We met with the FAC chairs
(or their equivalents) to determine how satisfied they were with the EPA's FAC
management and to identify best practices and suggestions for improvement.
Of the 84 products created by the FACs in our review from FY 2013 through
FY 2015, we randomly selected and analyzed two products from each FAC,5 for a
total of 13 products. Using internal control standards discussed in the "Federal
Internal Control Standards" section above, we determined whether (1) the EPA
directly responded to the FACs about each product, (2) the responses were
published online on the public FAC websites, (3) the responses described if
5 We sampled two products from each S&R FAC with the exception of BOSC and CSAC, which only developed
one product and zero products, respectively, during the sampling timeframe. Therefore, our random sample totaled
13 products.
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and/or how the EPA will address the FAC recommendations, and (4) the DFO
and/or the program office tracked the status of recommendations.
Additionally, we reviewed the following guidance documents, prior reports and
online sources:
• FACA, 5 U.S.C. Appendix 2, 1972 (as amended).
• GAO, Standards for Internal Control in the Federal Government,
GAO-14-704G, September 2014.
• OMB Circular No. A-123, Management's Responsibility for Enterprise
Risk Management and Internal Control, July 15, 2016.
• GSA FACA Database and Draft DFO Help Manual.
• EPA FAC charters,6 2012 FACA Handbook, and annual call memorandum
to program offices for SAB and other FAC information.
• EPA, Science and Technology Policy Council Peer Review Handbook,
4th edition, October 2015.
• EPA OIG, 16-P-0246, EPA Cannot Assess Results and Benefits of Its
Environmental Education Program, July 29, 2016.7
• EPA FAC public websites.
Limitations
We determined that the GSA FACA Database should not be used to help
accomplish our objectives or be included as part of our findings. Our review of
the GSA FACA Database, which is outside of the EPA's control, revealed
limitations in how the EPA tracked the number and status of
FAC recommendations for this database. For example, some DFOs count each
FAC product as one recommendation, even though the product may contain
multiple recommendations. DFOs also acknowledged that the number of
recommendations marked as implemented in the GSA FACA Database is often
based on best estimates. Additionally, the GSA FACA Database tracks
recommendations made and implemented since the inception of FACA.
Results of Review
Overall, we found that the EPA has an adequate system of controls to engage with
and manage the recommendations and advice from the agency's S&R FACs. Our
random sample analysis of products created by S&R FACs from FY 2013 through
FY 2015 indicated that the controls are effective. The FAC chairs we interviewed
6 Charters specify the FACs' missions and general operational characteristics.
7 This report scope includes the National Environmental Education Advisory Committee and notes that, although
FACA does not require recommendations to be acted upon, "GAO internal control standards require that the
findings of audits and other reviews be promptly resolved. As such, the EPA should promptly review and resolve
recommendations." The report further notes that resolution does not mean that the EPA must implement the
recommendations but that it should have a documented resolution for recommendations.
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were generally satisfied with the agency's management of their committees and
the agency's responsiveness to the FAC recommendations; however, several FAC
chairs noted suggestions for improvement. We also identified areas where the
EPA could enhance public transparency regarding how the agency responds to
and tracks FAC recommendations.
EPA's System of Controls Are Effective
Consistent with the GAO's and OMB's internal control standards, the EPA has a
system of controls to engage with and manage the recommendations and advice
from FACs. OROM provides training to new DFOs, usually on an annual basis,
and hosts quarterly meetings with DFOs. OROM also advises DFOs and any
managers and staff who will be working with FACs to take the FACA training
offered by the GS A. OROM's training does not, however, highlight the
importance of posting responses online, consistent with the agency's Scientific
Integrity Policy for transparency, nor does it highlight the need for the DFO to
track the status of FAC recommendations. During interviews, DFOs noted that
OROM and the CMO do provide guidance on charter renewal and the committee
membership process.
Overall, we found the agency's internal system of controls to manage the
recommendations and advice from FACs to be effective. We determined
effectiveness by assessing whether (1) the EPA provided a response to FAC
products, including information regarding how the agency would address any
recommendations made; (2) the status of FAC recommendations was being
tracked; and (3) the FAC chairs were satisfied with how the agency engages with
and manages committee advice. We reviewed 13 randomly selected products
from seven FACs.
(1) EPA Addressed All Sample Products
Our sample review found that the agency directly responded to 10 of the 13 FAC
products with information on how the agency will address recommendations. The
three remaining FAC products that did not receive direct responses were being
addressed at the program office level. All 10 direct responses provided to FACs
were posted on the public FAC websites. Table 3 describes the findings from our
sample review in more detail.
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Table 3: Agency management of selected S&R FAC products
FACA report
Agency provided
direct response
Response
posted
online
Recommendations
addressed
BOSC
Strategic Research Planning for 2016-2019: A Joint
Report ofthe SAB and BOSC (2015)
Yes
Yes
Yes
CASAC
CASAC Review ofthe EPA's Integrated Science
Assessment for Oxides of Nitrogen—Health Criteria
(First External Review Draft—November 2013) (2014)
Yes
Yes
Yes
CASAC Review ofthe EPA's Second Draft Policy
Assessment for the Review of the Ozone National
Ambient Air Quality Standards (2014)
Yes
Yes
Yes
CHPAC
Re: CASAC Review ofthe Health Risk and Exposure
Assessment for Ozone and Policy Assessment for the
Review ofthe Ozone NAAQS: Second External
Review Drafts (2014)
N/Aa
N/A
Yes
Re: Human Health Benchmarks for Pesticides:
A Missed Opportunity (2013)
Yes
Yes
Yes
ELAB
Re: Selected Ion Monitoring (2014)
Yes
Yes
Yes
Recommendations Regarding the State of National
Accreditation (2012)
Yes
Yesb
Yes
FIFRA SAP
Integrated Endocrine Bioactivity and Exposure-Based
Prioritization and Screening (2015)
No
No
Yes
RNAi Technology as a Pesticide: Problem Formulation
for Human Health and Ecological Risk Assessment
(2014)
No
No
Yes
HSRB
April 8-9, 2014 EPA HSRB Meeting Report (2014)
Yes
Yes
Yes
April 22-23, 2015 EPA HSRB Meeting Report (2015)
Yes
Yes
Yes
SAB
SAB Advice on Advancing the Application of CompTox
Research for EPA Chemical Assessments (2014)
Yes
Yes
Yes
SAB Review ofthe Draft EPA Report Connectivity
of Streams and Wetlands to Downstream Waters:
A Review and Synthesis of the Scientific Evidence
(2014)
Yes
Yes
Yes
Summary of Results
10 of 13
10 of 13
13 of 13
Source: OIG analysis based on review of sample FAC products.
a This CHPAC report was addressed to another FAC (CASAC); as such, an agency response was not required
to be sent to CHPAC.
b During the course of our review, the agency response to the second ELAB report was unavailable. In the
agency's comments on our draft report, the link to the response was provided. We updated the final report with
the agency's information.
As shown in Table 3, three FAC products (one CHPAC product and two FIFRA
SAP products) did not receive direct responses from the agency. The Office of
Chemical Safety and Pollution Prevention's Office of Pesticide Programs and the
Office of Science Coordination and Policy are the lead offices responsible for
providing responses to the FIFRA SAP recommendations. While these program
offices did not provide responses directly to FIFRA SAP for the two reports
reviewed, they developed tables with information on how the agency has
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addressed or is addressing the recommendations. The CHPAC report that did not
receive a direct response was addressed to another advisory committee and
therefore did not require a response from the agency.
The EPA could improve transparency by
providing direct responses to all FAC
products. In addition, all agency responses
should be published online, consistent with
the EPA's Scientific Integrity Policy. For
example, during the course of this review, the
ELAB DFO already indicated plans to revise
ELAB's website to post agency responses
adjacent to committee products.
(2) EPA Tracked All Recommendations
Each of the FAC recommendations in our sample has either been addressed and
does not require further tracking or is being tracked by the program office. For
example, the Office of Pesticide Programs and the Office of Science Coordination
and Policy have developed tables detailing how the agency addresses each FAC
recommendation within their purview.
Although program offices typically track the status of any agreed-upon actions,
this information is not typically shared with the DFOs. The DFOs are supposed to
act as a liaison between the public, the FACs and the EPA; however, some DFOs
directed us to the program offices for the status of the recommendations.8 While
we were able to determine the status of recommendations from the program
offices, it took time to receive this information from the EPA staff responsible for
providing it. Accessing documents from program offices would likely be a more
difficult process for the general public.
To allow for easy public access to the status of agreed-upon recommendations,
DFOs could work closely with program officials to obtain updates to track the
status of FAC recommendations. For example, the BOSC DFO has stated they are
in the process of creating a spreadsheet for this purpose.
(3) FAC Chairs Satisfied but Identified Areas for Improvement
Overall, the FAC chairs we interviewed as part of our review expressed
satisfaction with the management of their committees and the work of the DFOs.
FAC chairs are satisfied with how the agency utilizes their FACs and with how
the agency responds to their committees' advice, even when a response is not
always expected. While some FAC chairs said charge questions come directly
from the agency with no input from their committees, others said their committees
can and do provide unsolicited advice and take a more proactive role in
8 The ELAB FAC DFO does track the status of the committee's recommendations.
The EPA's Scientific Integrity
Policy promotes access to
scientific information by making it
available online in open formats
and in a timely manner. The
EPA's posting of FAC products
and the agency's response to
FAC recommendations align with
this policy.
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developing new charge questions. FAC chairs identified the following suggestions
to improve the management of FAC membership and meeting processes:
1. Allow FAC chairs to provide input into committee member selection to
ensure necessary expertise.
2. Ensure each FAC has a core of permanent panel members who attend all
meetings to provide perspective and help direct the efforts of ad hoc
members. Cultivate leadership of the permanent FAC panel members and
chairs.
3. Clarify the policy context of the charge questions and/or how the
recommendations are going to be utilized so that the FAC can provide
more constructive advice to the agency.
4. Provide the FACs with sufficient background material prior to all
meetings so they can be more prepared to provide advice to the agency,
particularly in cases where the agency is meeting with the committee to
discuss broader topics.
5. Specify procedures for how the committee should develop conclusions,
whether or not consensus is required.
6. Differentiate recommendations from suggestions, with the expectation that
all recommendations require agency response but suggestions do not
necessarily require a response. More significant recommendations could
be further classified as "strong," or the committee could prioritize
recommendations in list form to help facilitate implementation.
Conclusion
Overall, we found the EPA's system of controls to manage the recommendations
and advice from S&R FACs to be effective. However, based on our review, we
identified areas where the agency can strengthen its controls with regard to
transparency and tracking the status of FAC recommendations. Providing direct
responses to all FAC products and posting all agency responses online are two
ways the EPA could improve transparency and also promote public access to
agency activities. In addition, to allow for easy access to the status of
recommendations, DFOs should be responsible for working closely with program
offices to track the status of FAC recommendations. The agency can also improve
its management of FACs by soliciting feedback from the FAC chairs.
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Recommendations
To strengthen and reinforce the EPA's system of controls for managing the
recommendations and advice from federal advisory committees and to improve
transparency, we recommend that the Assistant Administrator for Administration
and Resources Management:
1. Update the EPA's Federal Advisory Committee Handbook to:
a. Direct Designated Federal Officers to maintain and keep the
federal advisory committee websites current, work closely with
program officials to provide a direct response to each federal
advisory committee product with information on how the
recommendations will be addressed, and make EPA responses
publicly available as soon as possible.
b. Direct Designated Federal Officers to work closely with other EPA
program officials to track the status of federal advisory committee
recommendations, to promote ease of public accessibility.
c. Direct the Federal Advisory Committee Management Division's
Director or his/her designee to collect feedback from active federal
advisory committee chairs on a regular basis to identify ways to
improve the utilization and management of federal advisory
committees.
2. Update the Designated Federal Officer training materials and incorporate
into the annual training that Designated Federal Officers are responsible
for maintaining federal advisory committee websites with current agency
responses and for working closely with other EPA program officials to
track the status of federal advisory committee recommendations.
Agency Response and OIG Evaluation
The EPA agreed with our recommendations. The agency provided acceptable
corrective actions for Recommendations 1.a through l.c and has completed
corrective actions for Recommendation 2. The agency also provided technical
comments on the draft report. Where appropriate, we incorporated changes to the
report based on the agency's technical comments. Appendix A contains the
agency's full response.
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Status of Recommendations and
Potential Monetary Benefits
RECOMMENDATIONS
Rec. Page
No. No.
Subject Status1
Action Official
Planned
Completion
Date
Potential
Monetary
Benefits
(in $000s)
1 11
Update the EPA's Federal Advisory Committee Handbook to: R
a. Direct Designated Federal Officers to maintain and keep the federal
advisory committee websites current, work closely with program
officials to provide a direct response to each federal advisory
committee product with information on how the recommendations
will be addressed, and make EPA responses publicly available as
Assistant Administrator
for Administration and
Resources
Management
12/31/17
soon as possible.
b. Direct Designated Federal Officers to work closely with other EPA
program officials to track the status of federal advisory committee
recommendations, to promote ease of public accessibility.
c. Direct the Federal Advisory Committee Management Division's
Director or his/her designee to collect feedback from active federal
advisory committee chairs on a regular basis to identify ways to
improve the utilization and management of federal advisory
committees.
2 11 Update the Designated Federal Officer training materials and incorporate C Assistant Administrator 2/2/17
into the annual training that Designated Federal Officers are responsible for Administration and
for maintaining federal advisory committee websites with current agency Resources
responses and for working closely with other EPA program officials to Management
track the status of federal advisory committee recommendations.
1 C = Corrective action completed.
R = Recommendation resolved with corrective action pending.
U = Recommendation unresolved with resolution efforts in progress.
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Appendix A
Agency Response to Draft Report
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
FEB 1 0 2017
OFFICE OF
ADMINISTRATION
AND RESOURCES
MANAGEMENT
MEMORANDUM
SUBJECT: Response to Office of Inspector General Draft Report No. OPE-F Y16-0024
EPA Has Adequate Controls to Manage Advice From Science and Research Federal
January 10, 2017
Thank you for the opportunity to respond to the issues and recommendations in the subject
draft report. Attachment One is a summary of the agency's overall position and its position on
each of the report recommendations. Attachment Two contains the three technical comments
on the report.
The Office of Administration and Resources Management believes the findings in the draft
report are fair and accurate and is pleased that the Office of Inspector General has found that the
system of controls to manage the recommendations and advice from federal advisory committees
to be effective. The OARM agrees with the recommendations and have provided high-level
intended corrective actions and estimated completion dates in response to each of the
recommendations. In addition, the OARM will advise the agency's Designated Federal Officers
about the recommendations and corrective actions at its quarterly DFO network meetings.
As agreed with Erin Barnes-Weaver, OIG Project Manager, the recommendations from the OIG
draft report have been revised as follows: 1) recommendations one, two, and three from the draft
report have been combined into one recommendation, 2) recommendation l.a. has been modified
to clarify the role of program officials in providing responses to FAC products, and 3) the
language in recommendation two has been corrected so that it aligns with recommendation l.b.
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FROM:
Donna J. Vizian, Acting Assistant Admin?
TO:
Arthur A. Elkins, Jr., Inspector General
Office of Inspector General
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If you have any questions regarding this response, please have your staff contact Monisha Harris,
director, Federal Advisory Committee Management Division, at (202) 564-0563.
Attachments
cc: John Reeder
Chris Robbins
John Showman
Louise P. Wise
Lynnann Hitchens
Michael Hardy
Monisha Harris
Megan Moreau
Lauren Lemley
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Attachment (1)
AGENCY'S RESPONSE TO REPORT RECOMMENDATIONS
No.
Recommendations
High-Level Intended
Corrective Action(s)
Estimated
Completion
Date
1.
Update the EPA's Federal Advisory
Committee Handbook to:
a. Direct the Designated Federal
Officers to maintain and keep the
federal advisory committee websites
current, work closely with program
officials to provide a direct response
to each FAC product with
information on how the
recommendations will be addressed,
and make the EPA responses
publicly available as soon as
possible.
b. Direct the DFOs to work closely with
other EPA program officials to track
the status of the FAC
recommendations, to promote ease of
public accessibility.
c. Direct the FAC management division
director's or his/her designee
to collect feedback from active FAC
chairs on a regular basis to identify
ways to improve the utilization and
management of the FACs.
The Office of Administration
and Resources Management
agrees with this
recommendation. The OARM
will update the EPA federal
advisory committee handbook
to codify these requirements.
December 31,
2017
2.
Update the Designated Federal Officer
training materials and incorporate into the
annual training that the DFOs are
responsible for maintaining the FAC's
websites with current agency responses and
for working closely with other EPA
program officials to track the status of the
FAC recommendations.
The OARM agrees with this
recommendation and has
updated the training materials
to incorporate the
recommended actions.
Completed
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Appendix B
Distribution
The Administrator
Assistant Administrator for Administration and Resources Management
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 for Administration and Resources Management
Director, Office of Resources, Operations and Management, Office of Administration and
Resources Management
Deputy Director, Office of Resources, Operations and Management, Office of Administration
and Resources Management
Audit Follow-Up Coordinator, Office of the Administrator
Audit Follow-Up Coordinator, Office of Administration and Resources Management
Audit Follow-Up Coordinator, Office of Air and Radiation
Audit Follow-Up Coordinator, Office of Chemical Safety and Pollution Prevention
Audit Follow-Up Coordinator, Office of Research and Development
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