U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF INSPECTOR GENERAL
Science and Research
To Ensure Greater Use of
Scientific Equipment, the
Office of Research and
Development Should Use
an Enterprise Approach to
Property Management
Report No. 15-P-0115
March 16, 2015

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Report Contributors:	Patrick Gilbride
Erin Barnes-Weaver
Todd Goldman
Raul Adrian
Derek Mulvihill
Abbreviations
CFR	Code of Federal Regulations
EPA	U.S. Environmental Protection Agency
NERL	National Exposure Research Laboratory
NHEERL National Health and Environmental Effects Research Laboratory
NRMRL	National Risk Management Research Laboratory
OIG	Office of Inspector General
ORD	Office of Research and Development
RTP	Research Triangle Park
Cover photo: A plasma mass spectrometer in the EPA's National Exposure Research
Laboratory in Research Triangle Park, North Carolina. (EPA OIG photo)
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
THE INSPECTOR GENERAL
March 16, 2015
MEMORANDUM
SUBJECT: To Ensure Greater Use of Scientific Equipment, the Office of Research and
Development Should Use an Enterprise Approach to Property Management
Report No. 15-P-0115
FROM: Arthur A. Elkins Jr.
TO:
Lek Kadeli, Acting Assistant Administrator
Office of Research and Development
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. EPA managers, in accordance with
established audit resolution procedures, will make final determinations on matters in this report.
The EPA offices with primary responsibility over the issues discussed in this report include the
laboratories within the Office of Research and Development as well as the Office of Administrative and
Research Support, which houses the National Asset Manager. Additionally, the EPA's Office of
Administration and Resources Management administers the personal property management program.
Action Required
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.
We will post this report to our website at http://www.epa.gov/oig.
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To Ensure Greater Use of Scientific Equipment,
the Office of Research and Development Should Use
an Enterprise Approach to Property Management
15-P-0115
Table of C
Purpose		1
Background		1
Agency Actions Prompted by OIG Work		3
Responsible Offices		3
Scope and Methodology		3
Results of Review		6
Conclusion		8
Recommendations		9
Agency Comments and OIG Evaluation		9
Status of Recommendations and Potential Monetary Benefits		10
Appendices
A Agency Response to Official Draft Report and OIG Comments	 11
B Distribution	 15
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Purpose
We conducted this review to determine whether the U.S. Environmental
Protection Agency (EPA) Office of Research and Development (ORD) has
adequate controls over research equipment—including safeguarding,
maintenance, calibration and utilization—to ensure that equipment may be relied
upon for EPA decision-making and reporting. During our review we decided to
shift the focus from data reliability to equipment utilized for decision making.
Background
Science at the EPA provides the foundation for credible decision-making to
safeguard human health and ecosystems from environmental pollutants. ORD is
the scientific research arm of the EPA and its research helps provide the
underpinning of science and technology for the agency. ORD conducts research in
14 facilities across the country, including three national laboratories we reviewed:
•	National Exposure Research Laboratory (NERL). NERL develops and
applies innovations in exposure science (i.e., study of methods,
measurements and models to assess and predict exposure of humans and
ecosystems to harmful environmental stressors). Headquartered in
Research Triangle Park (RTP), North Carolina, NERL conducts its work
across six divisions in four geographic locations.
•	National Health and Environmental Effects Research Laboratory
(NHEERL). NHEERL serves as the agency's focal point for scientific
research on the effects of contaminants and environmental stressors on
human health and ecosystem integrity. Also headquartered in RTP,
NHEERL conducts work across seven divisions in eight locations.
•	National Risk Management Research Laboratory (NRMRL).
NRMRL focuses on environmental problem-solving to determine what
environmental risks exist and how to manage those risks to protect human
health and the environment. Headquartered in Cincinnati, Ohio, NRMRL
conducts its work in five divisions in four locations.
To accomplish its mission, ORD uses sensitive and often expensive laboratory
and field testing equipment. ORD's reported capital equipment—those pieces
over $75,000—totaled nearly $73 million.1 ORD's fiscal years 2013 and 2014
Federal Managers' Financial Integrity Act assurance letters list scientific
equipment as a key area in internal control risk assessment protocols.
1 This amount reflects purchases through ORD's Procurement and Acquisition of Capital Equipment system. The
amount does not reflect any purchases over $75,000 that individual laboratories made on their own, nor does it
include any scientific equipment valued at less than $75,000 (e.g., pipettes, balances).
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Additionally, ORD included annual equipment and physical property inventories
as part of multi-year review plans.
Within the past 2 years, ORD created a National Asset Management position. The
National Asset Manager serves as the ORD-wide property liaison, coordinates
annual equipment and property inventories, and facilitates property transfer or
disposal throughout ORD. The National Asset Manager also indicated that each
ORD laboratory division has officers for property management, accountability
and utilization.
Federal property management regulations in the Code of Federal Regulations
(CFR), at 41 CFR 101, include the following requirements:
Section
101-25.109-1
Federal laboratories must be inspected at least every 2 years to
determine if any idle or unneeded equipment exists. Equipment
identified as idle or unneeded shall be reassigned as needed within
the laboratory, placed in an equipment pool, or declared excess and
made available to other agencies.
Section
101-25.109-2
Federal laboratories shall establish equipment pools so that
laboratory and research equipment can be shared or allocated on a
temporary basis to laboratory activities and individuals whose
average use does not warrant the assignment of the equipment on a
permanent basis.2
Federal regulations at 41 CFR 101 also requires the agency head to ensure
compliance and conduct periodic independent reviews to determine effectiveness
and make modifications.3
Additionally, the Federal Property and Administrative Services Act requires that
each agency:
1.	Maintain adequate inventory controls and accountability systems for the
property under its control.
2.	Continuously survey property under its control to determine which is
excess property, and promptly report such property to the administrator.4
3.	Perform the care and handling of such excess property.
4.	Transfer or dispose of such property as promptly as possible in accordance
with authority delegated by and regulations prescribed by the
administrator.5
2	This section goes on to note that: "Where the establishment of a physical pool would be economically unfeasible
due to excessive transportation and handling costs, limited personnel resources, or limited space, pooling may be
accomplished by means of equipment listings." Elsewhere in this report we describe the need for such a list.
3	Section 101-25.109-l(d).
4	The Act distinguishes excess and surplus property. Excess property is that no longer required by a federal agency,
whereas surplus property is that no longer required by any federal agency. 40 U.S.C. §102(3), 40 U.S.C §102(10).
5	40 U.S.C. §524(a)(5).
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5.	Make reassignments of property among activities within the agency when
such property is determined to be no longer required for the purposes of
the appropriation from which it was purchased.
6.	Transfer excess property under its control to other federal agencies.
7.	Obtain excess property from other federal agencies.6
EPA Policy 4832, Personal Property and Procedures Manual, describes the
agency's roles and responsibilities regarding personal property. The EPA's Office
of Administration and Resources Management administers the personal property
management program but, outside headquarters, delegates specific responsibilities
to Regional and Assistant Administrators. The agency's personal property
program is managed in the Compass Data Warehouse through 24 accountable
areas based on geographic locations. For example, each ORD facility has its own
accountable area. Overall responsibility for managing day-to-day property
management activities resides with custodial officers7 such as those at the ORD
laboratory division level.
Agency Actions Prompted by OIG Work
As a result of our EPA Office of Inspector General (OIG) work, ORD's National
Asset Manager has started developing an ORD-wide list of capital equipment. In
addition, two national laboratories started excessing idle equipment found during
our site visits.
Responsible Offices
The EPA offices with primary responsibility over the issues discussed in this
report include the laboratories we reviewed within ORD as well as the Office of
Administrative and Research Support, which houses the National Asset Manager.
Additionally, as noted above, the EPA's Office of Administration and Resources
Management administers the personal property management program.
Scope and Methodology
We conducted our review from April 2014 to January 2015. 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.
6	40 U.S.C. §524(b)(3).
7	ORD fills custodial officer positions with laboratory staff. EPA's Office of Administration and Resources
Management staffs the property accountable and utilization officer positions.
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To address our objective, we reviewed relevant materials pertaining to the use,
calibration, maintenance and safeguarding of scientific equipment, including
applicable federal regulations and EPA policies and procedures. We interviewed
key staff within ORD, the three national ORD laboratories in our scope, and the
Office of Administration and Resources Management.
To test controls over ORD scientific equipment, we made two site visits. We first
visited NERL, NHEERL and NRMRL facilities in RTP, North Carolina, given
their close proximity to each other and high dollar value equipment within each
laboratory (the three laboratories have 117 items each valued over $100,000).
Next we visited NERL and NRMRL facilities in Cincinnati, Ohio, to test controls
over equipment in a smaller facility. For each site visit, we used Compass Data
Warehouse8 information to develop judgmental samples of scientific equipment to
review. Our samples included equipment with acquisition costs that ranged from
$25,000 to $100,000 and equipment with costs over $100,000. We also randomly
selected items while touring each laboratory.
•	In RTP the sample included 49 pieces of equipment valued at $7.1 million:
o 11 pieces between $25,000 and $100,000.
o 27 pieces over $100,000.
o 11 randomly selected pieces that each had an acquisition cost of
less than $25,000.
•	In Cincinnati the sample included 50 pieces of equipment valued at
$9.8 million:
o 19 pieces between $25,000 and $100,000.
o 29 pieces over $100,000.
o 2 randomly selected pieces that each had an acquisition cost of less
than $25,000.
To test safeguarding, we observed that ORD housed all scientific equipment in
our sample in secure locations (i.e., buildings had security guards, badges were
required for building access, and rooms housing equipment were locked). To test
maintenance, calibration and usage, we developed a standard template to review
each piece of scientific equipment in our sample. For example, we checked
equipment logs and other records to ensure that labs performed calibration and
maintenance. Our calibration testing focused on equipment in Cincinnati where,
after providing laboratory staff with an equipment list in advance, we saw
evidence of calibration documentation for all actively used pieces in our sample.
We could not opine on the quality of calibrations; rather, we determined whether
they were conducted. Determining the quality of calibrations for data reliability
would require a detailed assessment of quality assurance materials outside of our
revised scope on equipment used for decision making. Regarding usage, our
8 The Compass Data Warehouse is an electronic interface used to access two separate databases (Momentum and
Maximo) housing the agency's financial and property management data.
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testing determined the date equipment was last utilized. At the close of our
testing, we queried individual laboratories to verify our sampling results and
obtain justifications for any equipment not utilized in the past 2 or more years.
Three prior reports relate to our review:
•	The first, issued in 2011 by the U.S. Government Accountability Office,9
found that the EPA had not taken an agencywide, coordinated approach to
managing its scientific efforts and did not manage its laboratory facilities
as part of an interrelated portfolio. It recommended, among other things,
that the EPA develop a coordinated planning process for its scientific
activities and improve physical and real property planning decisions
across all laboratories. The EPA generally agreed with these findings and
recommendations. The EPA said that, beginning in fiscal year 2011, the
agency added coding to track operating costs at program-funded
laboratory facilities not previously tracked. The EPA also said it would
review options for improving data reliability and completeness for the
remaining labs within its laboratory enterprise. Additionally, to address
some of the recommendations, the EPA formed a cross-agency workgroup
led by the Office of the Science Advisor. One initiative by this group was
to commission the National Academy review mentioned in the next bullet.
•	In September 2014, the National Academy of Sciences10 similarly
observed how EPA laboratories could become more effective and efficient
through rethinking the agency's laboratories from an enterprise
perspective. That report noted that the EPA's laboratories have various
processes for managing and acquiring laboratory equipment, but the
processes and inventory tools are not connected throughout the agency.
The report recommended that the EPA link inventory of equipment over
$500,000 in all laboratories, without regard to mission, to an agencywide
accessible process. The report also recommended that the EPA explore
shared use of laboratory equipment in other parts of the agency before
investment in large capital equipment. The report did not indicate whether
the EPA agreed with the findings and recommendations.11
•	In December 2014, the EPA OIG issued a report12 on the need for better
management of personal property in EPA warehouses. That report found
that the EPA did not adequately inventory property nor provide adequate
oversight to ensure effective and efficient use of EPA resources. The
9	U.S. Government Accountability Office report, Environmental Protection Agency: To Better Fulfill Its Mission,
EPA Needs aMore Coordinated Approach to Managing Its Laboratories (GAO-11-347), July 25, 2011.
10	National Academy of Sciences report, Rethinking the Components, Coordination, and Management of the
U.S. Environmental Protection Agency Laboratories (ISBN 978-0309-31237-0), September 5, 2014.
11	ORD said that, as a rule, the EPA does not respond to specific National Academy report recommendations as it
does with Government Accountability Office and EPA OIG reports.
12	EP A OIG report, EPA Needs Better Management of Personal Property in Warehouses (Report No. 15-P-0033),
December 8, 2014.
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report recommended, among other things, holding management and staff
accountable for timely transfer or disposal of excess personal property
according to agency policy, and updating agencywide policy to prevent
long-term storage of personal property beyond a year that does not satisfy
an immediate need. The agency agreed with all recommendations and the
OIG closed the two recommendations we cited at the time of report
issuance. Specifically, the agency noted in its Management Audits
Tracking System that Property Bulletin 14-004 (dated January 8, 2014)
addresses transaction times and accountability for timely transfer or
disposal of personal property as well as long-term property storage. The
EPA further noted that long-term storage should not be determined by
immediate need but rather by whether an item that will be needed in the
future is readily available from outside sources, or whether it is more cost
effective to store the item for future use.
Results of Review
The EPA does not manage its scientific equipment as a business unit or enterprise.
ORD managers and staff are not aware of federal property management
requirements in 41 CFR 101 that require regular equipment inspection
walkthroughs every 2 years and equipment pools to maximize utilization. The
Federal Property and Administrative Services Act requires regular monitoring to
timely identify and dispose of obsolete items. ORD has not created a
comprehensive, officewide scientific equipment list that would make ORD's
resources visible officewide and agencywide for key research decision-making.
Additionally, ORD does not have clear lines of authority or responsibility over
equipment accountability and usage. While the National Asset Manager position
is new to ORD within the past 2 years, the current manager said he received no
formal training, has had very little coordination with custodial officers, and
initially focused on buildings more than equipment.
Our review of a sample of research equipment within three laboratories charged
with risk management and exposure research found that 30 percent (or 30 of 99
pieces) had not been utilized for 2 to 14 years, as shown in Table 1:
Table 1: Number and dollar value of idle equipment in sample

Number
Value of
Number
Value of idle
Percent idle of

sampled
sample*
idle
equipment
total sampled
NERL
33
$3,030,639
15
$1,034,117
45.45%
NHEERL
18
3,490,172
2
107,604
11.11%
NRMRL
48
10,218,803
13
1,811,382
27.08%
TOTAL
99
$16,739,614
30
$2,953,103
30.30%
* Value based on acquisition amounts pulled from EPA's Compass Data Warehouse.
Source: OIG analysis of equipment sampled at three national laboratories.
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The laboratories cited various reasons for idle equipment:
•	NERL. Of the 15 pieces of idle equipment, seven pieces pertained to a
rivers and streams research project that ended in June 2012. Additionally,
two idle pieces were used for large-scale nutrient analyses no longer being
done. NERL said that remaining idle pieces were either obsolete
(two pieces), would be used in future water research (two pieces), or
would be made available ORD-wide (one piece).
•	NHEERL. Both pieces of idle equipment had not been used in 3 years.
The idle pieces—a flow cytometer and an animal transfer station—pertain,
respectively, to the EPA's National Ambient Air Quality Standards and
ORD's Air, Climate, and Energy research programs. NHEERL justified
retaining both pieces of idle equipment as backup in case primary pieces
of research equipment failed.
•	NRMRL. For its 13 pieces of idle equipment, NRMRL said:
o One piece with an unknown last usage date is being used for parts,
o Two pieces not utilized since 2012 needed repair. NRMRL used
the two items for monitoring organic chemical synthesis reactions
and reducing chemicals formed during drinking water disinfection.
For one item, NRMRL did not have the funds to purchase a new
computer and operating system to run the equipment. NRMRL
plans to purchase these items and utilize the equipment once
repaired. Similarly, for the other item, the equipment was idle
while awaiting a replacement computer, software upgrade and
installation of a new detector. All have since been received and the
instrument is now back in use.
o Four pieces are obsolete.13 One item, a formaldehyde monitor to
evaluate emissions in buildings/materials, has not been used since
2002. Additionally, a laser used to improve data on compounds for
exposure assessments has not been used since 2001.
o Six pieces have no related active research. These pieces were last
used from 2009 to 2011 and pertained to—among other areas—
mercury, indoor air, vapor intrusion and particulate matter.
Staff on ORD's Management Council and its Capital Equipment Committee said
they were unfamiliar with regulatory requirements. As such, ORD's National Asset
Manager said that independent walk-throughs presently occur every 3 to 4 years
and that, instead of equipment pools, ORD sends informal emails on available
equipment to agency personal property managers. While ORD's National Asset
Manager said divisions annually certify property inventories, we nevertheless
found idle equipment that laboratories agreed were obsolete and could be excessed.
13 These four pieces, together with the two NERL pieces mentioned in the first bullet, means that six of 99 pieces we
sampled (or 6 percent) were obsolete.
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During our review, ORD could not provide us with a comprehensive officewide list
of all of its scientific equipment. ORD said that it uses the agency's Compass Data
Warehouse and a complete inventory can be obtained from this database.
Nevertheless, ORD did not provide us with a complete inventory. ORD's National
Asset Manager is developing an ORD-wide list of equipment valued at $75,000 or
more, but it does not include equipment valued at less than $75,000. Additionally,
the Office of Administration and Resources Management's Agency Property
Management Officer recognized that the current accountable area structure—based
on geographic locations—is incompatible with the requirements of EPA Policy
4832. As a result, the Agency Property Management Officer said that each program
office, such as ORD, will be moving to a single accountable area. ORD said that
the EPA is soon launching a new property system (Sunflower) which should make
it easier [than Compass] to navigate and create sub-inventories.
Risks exist by not managing ORD property as a program or an interconnected
business division. For example, unclear lines of authority could lead to idle
scientific equipment due to confusion over the person(s) responsible to ensure
usage. Moreover, absent an ORD-wide equipment list, ORD does not know the
total value of its scientific equipment and, further, could misspend funds by
purchasing duplicative items. Additionally, ORD research staff—and agency
program office customers—may not know whether a needed item for air and
water research is available for use. As such, valuable scientific equipment could
sit idle when there might be a demand for it elsewhere in ORD or the agency.
According to ORD, there may be good reasons to retain equipment:
•	Keeping older pieces of equipment as backups for newer instrumentation
can result in potential cost savings due to having a readily available source
of spare parts for some types of equipment.
•	The cost to ship high-priced and sensitive equipment across the country
can be very expensive and the equipment can be damaged.
•	Moving sensitive analytical equipment often voids the manufacturer's
warranty and makes it difficult to have a maintenance contract.
•	When an analytical instrument is shipped to another lab, that lab must
have the expertise to operate, repair and maintain the instrument.
•	Even though equipment is not currently being utilized, it still contributes
to the lab's research capabilities, which allows the lab to quickly adapt to
changing mission without having to repurchase the equipment.
Conclusion
To minimize risks of having idle equipment and/or misspending funds on
duplicative equipment, ORD should develop and implement a plan to enhance
program controls and ensure compliance with federal property regulations. Better
property management would aid in decision-making on the utilization of current
equipment as well as the need to purchase new equipment for environmental risk
management and exposure research.
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Recommendations
We recommend that the Assistant Administrator for Research and Development:
1.	Develop an ORD equipment list and a system to manage it that will meet
requirements established by the Federal Property and Administrative
Services Act and by the EPA Office of Administration and Resources
Management—which has EPA-wide responsibility for developing and
establishing an effective and efficient agencywide property management
program—to maintain adequate inventory controls and accountability
systems for the property. The equipment list should have standard
fields/nomenclature understood by all laboratories. The information
compiled should also be relevant to equipment list users.
2.	Create an equipment pool that provides relevant and accurate data which
is updated and maintained per requirements in federal property
management regulations.
3.	Establish regular equipment utilization walkthroughs and formal reporting
and follow-up of the results thereof, including updates to equipment lists
per requirements in federal property management regulations.
4.	Conduct independent reviews of the equipment pool procedures to ensure
their continued effectiveness per requirements in federal property
management regulations.
5.	Define the role, responsibility and authority of the National Asset
Manager within the framework of the EPA's personal property policies
and procedures.
6.	Excess obsolete equipment identified during OIG site visits.
Agency Comments and OIG Evaluation
In its response to our official draft report, ORD did not agree with the wording of
Recommendation 1 and suggested some specific additional wording to reflect the
property management responsibility that ORD shares with the EPA's Office of
Administration and Resources Management. We agreed and made the proposed
changes. ORD subsequently agreed with Recommendation 1, which is resolved
and open with agreed-to actions due for completion in October 2015.
ORD agreed with Recommendations 2 through 6, and each is resolved and open
with agreed-to actions due for completion in June 2015.
Appendix A includes ORD's full response to the official draft report and the
OIG's comments.
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Status of Recommendations and
Potential Monetary Benefits
RECOMMENDATIONS
POTENTIAL MONETARY
BENEFITS (In $000s)
Rec. No.
Page
No.
Subject
Status1
Action Official
Planned
Completion
Date
Claimed
Amount
Ag reed-To
Amount
Develop an ORD equipment list and a system to
manage it that will meet requirements established by
the Federal Property and Administrative Services Act
and by the EPA Office of Administration and
Resources Management—which has EPA-wide
responsibility for developing and establishing an
effective and efficient agencywide property
management program—to maintain adequate
inventory controls and accountability systems for the
property. The equipment list should have standard
fields/nomenclature understood by all laboratories.
The information compiled should also be relevant to
equipment list users.
Create an equipment pool that provides relevant and
accurate data which is updated and maintained per
requirements in federal property management
regulations.
Establish regular equipment utilization walkthroughs
and formal reporting and follow-up of the results
thereof, including updates to equipment lists per
requirements in federal property management
regulations.
Conduct independent reviews of the equipment pool
procedures to ensure their continued effectiveness
per requirements in federal property management
regulations.
Define the role, responsibility and authority of the
National Asset Manager within the framework of the
EPA's personal property policies and procedures.
Excess obsolete equipment identified during OIG
site visits.
Assistant Administrator for 10/1/15
Research and Development
Assistant Administrator for 6/1 /15
Research and Development
Assistant Administrator for 6/1 /15
Research and Development
Assistant Administrator for 6/1 /15
Research and Development
Assistant Administrator for	6/1 /15
Research and Development
Assistant Administrator for	6/1115
Research and Development
0 = Recommendation is open with agreed-to corrective actions pending.
C = Recommendation is closed with all agreed-to actions completed.
U = Recommendation is unresolved with resolution efforts in progress.
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Appendix A
Agency Response to Official Draft Report
and OIG Comments
February 11, 2015
MEMORANDUM
SUBJECT: Response to the Office of Inspector General (OIG) Draft Report, To Ensure
Greater Use of Scientific Equipment, the Office of Research and Development
Should Use an Enterprise Approach to Property Management, Project Number
OPE-FY14-0024
FROM: Lek Kadeli, Acting Assistant Administrator /s/
TO:	Arthur A. Elkins, Jr., Inspector General
Office of Inspector General
Thank you for the opportunity to respond to the OIG draft report titled To Ensure Greater Use of
Scientific Equipment, the Office of Research and Development Should Use an Enterprise
Approach to Property Management. As you know, sound science is a foundation of EPA's work
and its mission to protect human health and the environment. One way we ensure sound
laboratory analysis and scientific results in ORD is by safeguarding, maintaining, and properly
calibrating our laboratory instruments and equipment. ORD agrees with and appreciates the
OIG's acknowledgement that ORD had no significant, reportable issues related to safeguarding,
maintaining or calibrating laboratory research instruments and equipment.
ORD is in full agreement with recommendations 2-6 described in the OIG draft report. ORD
corrective actions for OIG recommendations 2 - 6 are outlined in Table 1 on page 3 of this
memorandum.
ORD does not agree with the wording of recommendation 1 in the draft OIG report because it
does not include sufficient context for evaluation and accountability. The current wording of the
OIG recommendation 1 is
"Develop an ORD equipment list and a system to manage it, per requirements in the
Federal Property and Administrative Services Act, to maintain adequate inventory
controls and accountability systems for the property. The equipment list should have
standard fields/nomenclature understood by all laboratories. The information compiled
should also be relevant to equipment list users."
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After a detailed review of the draft OIG report, ORD believes that the wording in
recommendation 1 should be expanded to include the following essential context:
"Develop an ORD equipment list and a system to manage it that will meet requirements
established by the Federal Property and Administrative Services Act and by the EPA
Office of Administration and Resources Management (OARM)—which has EPA-wide
responsibility for developing and establishing an effective and efficient agency-wide
property management program—to maintain adequate inventory controls and
accountability systems for the property. The equipment list should have standard
fields/nomenclature understood by all laboratories. The information compiled should also
be relevant to equipment list users."
One reason to change the wording in recommendation 1 is that the draft OIG report
acknowledges (on page 3) that EPA's Office of Administration and Resources Management
(OARM) has agency-wide responsibility for developing and establishing an effective and
efficient Agency-wide property management program—and that the 4832 EPA Personal
Property Policy and Procedures manual is the Agency's primary and authoritative reference for
property management. A second reason to change the wording in recommendation 1 is that the
draft OIG report does not include one important fact: that ORD works with OARM and with the
systems it establishes for effective and efficient property management. A third reason to change
the wording in recommendation 1 is that the ORD revision more accurately describes the context
for evaluation and accountability.
The ORD corrective actions for this recommendation—based on the recommended change in
wording to recommendation 1—are outlined in Table 2 on page 4 of this memorandum.
OIG Comment #1: We concur with ORD's suggested edits to our first recommendation and
revised our report accordingly.
In summary, to address the OIG's overall findings and recommendations, ORD will take actions
described in Tables 1 and 2 to improve its protocols for documenting and managing utilization of
laboratory equipment, for identifying potential laboratory equipment for pooling, and for
removing obsolete laboratory equipment during walk-throughs. ORD is looking forward to
strengthening its systematic approach in these areas to ensure improved use of its laboratory
instruments and equipment.
Should you or your staff have any questions, please contact Pai-Yei Whung, Director of
ORD/OARS, at 919-541-7963.
cc: Tom Burke
Bob Kavlock
Pai-Yei Whung
Amy Battaglia
ORD Laboratory Directors
15-P-0115
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Table 1.
ORD Corrective Actions based on ORD Agreement with Proposed OIG Recommendations
#2-6
No.
OIG Recommendation
Responsible
Office
ORD Corrective Action
Estimated
Completion
Date

2
Create an equipment pool that
provides relevant and accurate
data which is updated and
maintained per requirements in
federal property management
regulations.
ORD/ OARS
National Asset
Manager
ORD will create an equipment pool
of available equipment. The
equipment pool will be maintained
by the National Asset Manager.
6/1/2015
3
Establish regular equipment
utilization walkthroughs and
formal reporting and follow up
of the results thereof including
updates to equipment lists per
requirements in federal
property management
regulations.
ORD/OARS
National Asset
Manager,
Division
Managers and
Division Property
Specialist
The National Asset Manager will
ensure each site is aware of the
biannual requirement to perform
equipment utilization
walkthroughs. This requirement is
different than an annual property
inventory. A list of underutilized
equipment will be maintained at
each site. Obsolete equipment will
be excessed.
6/1/2015
4
Conduct independent reviews
of the equipment pool
procedures to ensure their
continued effectiveness per
requirements in federal
property management
regulations.
ORD/OARS
National Asset
Manager and
Property
Specialist
The National Asset Manager and a
selection of property specialists will
review the equipment pool
procedures for ORD.
Findings/Recommendations will be
forwarded to ORD Management for
review/implementation.
6/1/2015
5
Define the role, responsibility
and authority of the National
Asset Manager within the
framework of the EPA's
personal property policies and
procedures.
ORD/OARS
Management
Specific roles, responsibilities, and
authority will be reflected in the
National Asset Manager Position
Description.
6/1/2015
6
Excess obsolete equipment
identified during our site visits.
ORD/OARS
National Asset
Manager,
Division
Managers and
Division Property
Specialist
The National Asset Manager will
work with the property specialist to
ensure this is accomplished. Prior
to excessing obsolete equipment,
items will be placed in the pool of
available equipment (see Finding 2)
if deemed necessary.
6/1/2015
OIG Comment #2: We believe ORD's planned corrective actions address our
recommendations. We will monitor the EPA's Management Audit Tracking System for more
specificity on ORD's completed actions to address our recommendations. These
recommendations are resolved and open with agreed-to actions pending.
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Table 2.
ORD Corrective Actions based on the ORD Change to Proposed OIG Recommendation # 1
No.
OIG
Recommendation
ORD Proposed Change to
OIG Recommendation
Responsible
Office
ORD Corrective Actions
Estimated
Completio
n Date






1
Develop an ORD
equipment list and a
system to manage it,
per requirements in
the Federal Property
and Administrative
Services Act, to
maintain adequate
inventory controls
and accountability
systems for the
property. The
equipment list should
have standard
fields/nomenclature
understood by all
laboratories. The
information compiled
should also be
relevant to
equipment list users.
Develop an ORD equipment
list and a system to manage
it that will meet
requirements established by
the Federal Property and
Administrative Services Act
and by the EPA Office of
Administration and
Research Management
(OARM)—which has EPA-
wide responsibility for
developing and establishing
an effective and efficient
agency-wide property
management program—to
maintain adequate inventory
controls and accountability
systems for the property.
The equipment list should
have standard
fields/nomenclature
understood by all
laboratories. The
information compiled
should also be relevant to
equipment list users.
ORD/OARS
National
Asset
Manager
1.	As ORD develops its
equipment list and
management system, ORD
initially will use the existing
inventory database used by
EPA and OARM—the
Compass Data Warehouse
(CDW). Although
cumbersome, the CDW has
standard fields and a
complete ORD inventory
can be obtained with this
database.
2.	When EPA and OARM
launch the agency's new
property management
system (Sunflower) later in
FY15, ORD will transition
its inventory data base to
this system.
3.	The ORD National Asset
Manager also will work
with OARM to determine if
changes are required to the
EPA Personal Property
Manual to comply with
requirements in the Federal
Property and Administrative
Services Act.
10/1/15
OIG Comment #3: We concur with ORD's edits to our first recommendation and we revised our
report accordingly. We believe ORD's planned actions address our recommendation. We will
monitor the EPA's Management Audit Tracking System for more specificity on ORD's completed
actions to address our recommendation. This recommendation is resolved and open with agreed-to
actions pending.
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Appendix B
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 for Science, Office of Research and Development
Deputy Assistant Administrator and Science Advisor, Office of Research and Development
Director, National Exposure Research Laboratory, Office of Research and Development
Director, National Health and Environmental Effects Research Laboratory, Office of Research
and Development
Director, National Risk Management Research Laboratory, Office of Research and Development
Audit Follow-Up Coordinator, Office of Research and Development
15-P-0115
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