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Report Contributors:	Laurie Adams
Daniel Carroll
Jerri Dorsey
Jeffrey Harris
Abbreviations
EPA
U.S. Environmental Protection Agency
FY
Fiscal Year
OIG
Office of Inspector General
PPA
Pollution Prevention Act of 1990
P2
Pollution Prevention
Cover photo: Photo of emissions from an industrial area. (EPA photo)
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More information at www.epa.gov/oiq/hotline.html.
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U.S. Environmental Protection Agency	15-P-0276
'i Office of Inspector General	Septembers 2015
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At a Glance
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Why We Did This Review
We conducted this review of
the U.S. Environmental
Protection Agency's (EPA's)
Pollution Prevention (P2) grant
activities to determine how the
EPA has ensured pollution
prevention goals are achieved
through P2 grants.
The Pollution Prevention Act of
1990 authorizes the EPA to
award grants to states and
tribes. The intent of this effort is
to encourage businesses to
adopt environmental strategies
and solutions that significantly
reduce or eliminate waste and
result in cost savings and
improved pollution controls.
The EPA has awarded over
$122 million in P2 grants in the
last 26 years. P2 results by
grantees are reported to, and
adjusted by, EPA regions and
headquarters before their
release to the public. P2 grant
results are used to substantiate
EPA performance on several
Government Performance and
Results Act goals.
This report addresses the
following EPA goal or
cross-agency strategy:
• Ensuring the safety of
chemicals and preventing
pollution.
Send all inquiries to our public
affairs office at (202) 566-2391
or visit www.epa.gov/oiq.
The full report is at:
www.epa.aov/oia/reports/2015/
20150904-15-P-0276.pdf
EPA Needs Accurate Data on Results of Pollution
Prevention Grants to Maintain Program Integrity and
Measure Effectiveness of Grants
What We Found
The EPA is unable to determine the extent to
which P2 grants achieved pollution prevention
goals. Neither headquarters nor the regions we
reviewed consistently implemented EPA quality
control guidance and practices when compiling
P2 grant results. In addition, we found reporting
and transcription errors. Because of the lack of
controls to ensure that results are reported
accurately and consistently, we found that:
Inaccurate reporting of
results misrepresents the
impacts of pollution
prevention activities
provided to the public, and
misinforms EPA
management on the
effectiveness of its
investment in the program.
•	Due to errors and inconsistent regional reporting, EPA headquarters
significantly modified results reported by the grantees to EPA regions. For
example, in our sample year of fiscal year 2011, the regions reported over
$200 million saved by incorporating pollution prevention practices. We found
headquarters reduced this amount of dollars saved by businesses by
58 percent. EPA headquarters revised initial results again 2 years later.
•	Errors in the reporting of grants results occurred. For example, one region
reported 17,000 gallons of water saved to headquarters instead of the
17,000,000 gallons actually reported by the grantee.
•	Reporting guidance was not applied consistently. For example, reported
fiscal year 2011 results associated with one state P2 leadership program
were reported at 10 percent, whereas in the following fiscal year the results
from the same activities were reported at 40 percent.
Inconsistent and arbitrary application of the measurement guidance hampers the
agency's ability to accurately report reliable grant program results. This creates a
risk for the integrity and value of the EPA's reported P2 achievements and
weakens confidence that the agency's pollution prevention goals have been
achieved.
Recommendations and Planned Agency Corrective Actions
We recommend that the Assistant Administrator for Chemical Safety and
Pollution Prevention: (1) implement the P2 GrantsPlus database to begin the
process for enhancing the reporting and recording of its P2 grants, and
(2) develop and implement controls to ensure accurate reporting of regional
results to headquarters and documentation of revisions made by headquarters.
The EPA agreed with our recommendations and proposed acceptable corrective
actions. All recommendations are resolved and no further response from the
agency is needed.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
THE INSPECTOR GENERAL
September 4, 2015
MEMORANDUM
SUBJECT: EPA Needs Accurate Data on Results of Pollution Prevention Grants to
Maintain Program Integrity and Measure Effectiveness of Grants
Report No. 15-P-0276
FROM: Arthur A. Elkins Jr.
TO:
Jim Jones, Assistant Administrator
Office of Chemical Safety and Pollution Prevention
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 audit resolution procedures.
The EPA office having primary responsibility for the issues evaluated in this report is the Office of
Chemical Safety and Pollution Prevention's Office of Pollution Prevention and Toxics.
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. 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 http://www.epa.gov/oig.
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EPA Needs Accurate Data on Results of
Pollution Prevention Grants to Maintain Program
Integrity and Measure Effectiveness of Grants
15-P-0276
Table of C
Purpose		1
Background		1
Responsible Office		4
Scope and Methodology		4
Prior OIG Report		5
Results of Review		6
Guidance and Controls Do Not Ensure Consistent and Accurate
Reporting of State P2 Program Results		6
Reported P2 Grant Results Cannot Be Reconciled Between
the Regions and Headquarters		8
Recent Agency Actions Prompted by OIG Work		9
Conclusions		10
Recommendations		10
Agency Comments and OIG Evaluation		10
Status of Recommendations and Potential Monetary Benefits		11
Appendices
A Agency's Response to Draft Report	 12
B Distribution	 14
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Purpose
Our objective was to determine how the U.S. Environmental Protection Agency
(EPA) has ensured pollution prevention goals are achieved through Pollution
Prevention (P2) grants.
Background
Pollution prevention is any practice that reduces, eliminates or prevents pollution
at its source, also known as "source reduction " Source reduction is fundamentally
different and more desirable than recycling, treatment and disposal. According to
the Pollution Prevention Act of 1990 (PPA),1 the United States annually produces
millions of tons of pollution and spends tens of billions of dollars per year
controlling this pollution. Reducing the amount of pollution produced should
mean a decrease in the control, treatment and disposal of waste as depicted in the
EPA's Waste Management Hierarchy in Figure L
Figure 1: The EPA's Waste Management Hierarchy
Source
Reduction \
Reuse and
Recycling
Treatment
Disposal
Waste Management Hierarchy
Prevent pollution by not
creating it in the first place.
Collect waste materials and
reuse or remanufacture.
Reduce toxicity and
release of pollutants.
Control pollution by storing
or burying waste.
ing
Source: The EPA.
Less pollution means less hazards posed to public health and the environment.
Various approaches can be applied to all pollution-generating activities, including
those found in the energy, agriculture, federal, consumer and industrial sectors.
For example, there are significant opportunities for industry to reduce or prevent
pollution at the source through cost-effective changes in production, operation
and raw materials use. Such changes offer industry substantial savings in reduced
raw material, pollution control and liability costs; and help protect the
environment and reduce risks to worker health and safety.
1 The Pollution Prevention Act of 1990; 42 U.S.C. § 13101 et seq.
15-P-0276
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The PPA established a national policy to achieve pollution prevention by reducing
industrial pollution at its source. The EPA implements the PPA through its P2
Program. The P2 Program seeks to alleviate environmental problems by achieving
significant reductions in the use of hazardous materials, energy and water;
reductions in the generation of greenhouse gases; cost savings; and increases in
the use of safer chemicals and products.
EPA Grants Fund Pollution Prevention Activities
PPA authorizes the EPA to award grants to state governments.2 The intent of this
effort is to assist state and tribal governments in encouraging businesses3 to adopt
environmental strategies and solutions that significantly reduce or eliminate waste
from the source. Annually, the EPA awards about 40 P2 grants to states and tribes
averaging $4.5 million. Over a 26-year period, the EPA has awarded over
$122 million in grants to support pollution prevention activities and develop state
pollution prevention programs. P2 grants are issued and managed by the EPA's
regional pollution prevention program offices, and the awarded amounts range
from $20,000 to $180,000 per grantee.
The P2 Program has five priority national focus areas for its grant activities:
1.	Greenhouse gas reduction.
2.	Toxic and hazardous materials reduction.
3.	Resource conservation.
4.	Business efficiency.
5.	P2 integration.
Additionally, each EPA region has a set of local priorities that highlight specific
environmental issues, projects and/or programs of significant interest to the
region. Grantees must address at least one national focus area and one regional
priority. The P2 grants should support activities that focus on:4
•	Institutionalizing P2 as an environmental management method.
•	Helping businesses establish prevention goals, providing on-site technical
assistance or training to businesses, and supporting outreach and research
endeavors.
•	Supporting data collection and analysis to curtail environmental
inefficiencies while increasing awareness of P2.
For the period we reviewed, we found that the EPA grants in Regions 1, 3 and 4
were awarded for various P2 activities, including:
2	The District of Columbia, state colleges and universities, federally-recognized Indian tribes, territories and
possessions of the United States are also eligible for funding.
3	Examples of businesses targeted include, but are not limited to: automotive, printing, dry cleaning, manufacturing,
agriculture, hospitality, and nonindustrial groups such as schools.
4	Catalogue of Federal Domestic Assistance No. 66.708.
15-P-0276
2
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•	Outreach activities including, workshops, webinars and production of
e-newsletters.
•	Development of resources to help promote sustainable stormwater
solutions.
•	Technical assistance such as providing advice to businesses on pollution
prevention strategies.
•	Recognition for companies that operate outstanding or innovative source
reduction programs.
•	Support of state leadership and environmental leadership activities.
Measuring P2 Grant Results
The PPA requires the EPA Administrator to establish appropriate means for
measuring the effectiveness of the state grants in promoting use of source reduction
techniques by businesses. In addition, the EPA's Environmental Results Policy
(EPA Order 5700.7A1) requires the grant applicant to provide qualitative and
quantitative estimates of expected outcomes and outputs on project activities and to
develop a plan for measuring and tracking their progress toward achieving the
expected outputs and outcomes prior to the award. The agency has four performance
metrics for measuring pollution prevention effectiveness (see Table 1).
Table 1: EPA pollution prevention performance measures supported by grants
Performance Metric
Description
Gallons of water reduced through
pollution prevention.
Counts the gallons of water reduced as a
result of water conservation.
Business, institutional and government
costs reduced through pollution
prevention.
Counts the amount of money saved from
incorporating pollution prevention practices
into the daily operations of government
agencies, businesses and institutions.5
Pounds of hazardous material reduced
through pollution prevention.
Counts the reduction of hazardous
substances, pollutants or contaminants
released to air, water and land; incorporated
into products; or used in an industrial process.
Metric tons of carbon dioxide equivalent
reduced or offset through pollution
prevention.
Counts the metric tons of carbon dioxide
equivalent reduced or offset.
Source: Office of Inspector General (OIG) developed based on fiscal year (FY) 2014
Office of Chemical Safety and Pollution Prevention National Program Manager Guidance.
Annual results from the P2 grants are used to substantiate the EPA's performance
on pollution prevention metrics. These are EPA Government Performance and
Results Act performance measures for which results are annually reported to
Congress, the Office of Management and Budget, and the public.
5 Implementing enviromnental and energy conserving opportunities can lead to the reduction of energy, water and
fuel usage, thereby producing considerable costs savings for businesses. Under P2 State and Tribal Assistance
Grants, only the cost savings to businesses are to be counted.
15-P-0276
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Grant recipients are required to report on the results of their activities.6
Specifically, all EPA grant recipients are required to submit interim and final
reports to the EPA that document their progress toward meeting the expected
outcomes and outputs. Figure 2 depicts the sequence of reporting final results.
The businesses or entities first report their P2 results to the state or tribal grantee.
The grantee reports these results to an EPA region. Regions analyze reported
results and make adjustments per agency guidance. The regions report the results
from all funded grantees to the EPA headquarters office annually. The EPA
headquarters office reviews the submitted results and makes additional
adjustments to address methodological issues or errors identified during their
review. The P2 grant results are combined with the results from other P2 activities
to demonstrate the annual accomplishments of the agency's pollution prevention
program.
Figure 2: P2 grants results reporting process
Grantees
submit results
to regions
Region P2
Coordinator
submits
regional totals
to EPA HQ
P2 grant
results
compiled by
EPA HQ
Clients/customers
submit results to
grantee
Source: OIG.
Responsible Office
The EPA office having primary responsibility for P2 grants is the Office of
Chemical Safety and Pollution Prevention's Office of Pollution Prevention and
Toxics.
Scope and Methodology
We conducted our work from October 2014 through June 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.
To answer the objective of determining how the EPA has ensured pollution
prevention goals are achieved through P2 grants, we reviewed the agency's
in-place controls to ensure that the grants were awarded for activities that were
consistent with PPA and aligned with P2 goals and regional priorities. We also
6 The agency makes available P2 Calculator spreadsheets on its website to help measure the environmental and
economic performance results of P2 activities.
15-P-0276
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reviewed goals and metrics related to quantifying the program's achievement of
pollution prevention.
We reviewed the PPA to determine its authority and intent with respect to
P2 grants and measurement requirements. We also reviewed relevant policies,
guidance documents, strategic plans and previous reports. Specifically, we
reviewed the agency's Regional P2 Measurement Guidance, dated October 19,
2012, and the subsequent measurement guidance, dated April 28, 2015. We also
reviewed the Pollution Prevention Grant Program request for proposals for
FYs 2011 and 2012 to review applicable measurement, reporting and data
requirements. Subsequently, we reviewed the Pollution Prevention Grant Program
request for proposals for FYs 2014 and 2015 to identify recent changes in
measurement, reporting and data requirements.
For the reported pollution prevention achievements in FYs 2011 and 2012, we
reviewed all the associated P2 grant results from Regions 1, 3 and 4.7 We
reviewed the files held by the EPA for those grants at each regional office.
Specifically, we reviewed the grant award and/or grantee application, the midyear
and final reports, and any documentation supporting the activities conducted and
the achievement toward P2.
We analyzed how the reported grant results are supported and the degree of
transparency in the reporting of P2 grants. This review included meetings with
headquarters and regional staff to understand the process used to collect data in
support of results, as well as, the controls in place to ensure results are accurate
and valid. We met with three regional P2 coordinators to discuss and review their
data sources used in reporting grant results. We also met with three grantees—
the states of North Carolina, Vermont and Virginia—in an effort to determine
whether reported claims are supported.
Prior OIG Report
EPA OIG Report No. 09-P-0088. Measuring and Reporting Performance Results
for the Pollution Prevention Program Need Improvement, issued January 28,
2009, sought to verify the accuracy of data provided for the Office of
Management and Budget's 2006 Program Assessment Rating Tool evaluation of
seven EPA P2 programs, and track EPA's follow-up actions. The OIG
recommended the development of new performance metrics, and a quality
assurance project plan to ensure the quality of environmental data. The agency
officials agreed with all of the recommendations and has reported that all
corrective actions are complete.
7 Our review focused on the most recent results data available: FYs 2011 and 2012. We reviewed all of the grants in
Regions 1, 3 and 4 that reported results during that period. In total, we reviewed 32 grants (36 percent of the
universe of grants) that reported results in that 2-year period.
15-P-0276
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Results of Review
The EPA is unable to determine the extent to which P2 grants achieve pollution
prevention goals because the agency lacks controls to ensure that the results from
the grants are reported accurately and consistently across EPA regions. We found
the agency has management controls in place to ensure P2 grants are funding
activities that align with the EPA's P2 goals.8 However, we found inconsistent
application of measurement guidance 9 and transposition errors in the EPA's
reported P2 grant results for FYs 2011 and 2012. The results generated from the
P2 grants are used by the agency to report achievements in pollution prevention,
and make up part of the agency's performance measures used for budget decisions
and the public's review. Inadequate guidance and lack of data quality controls
hamper the agency's ability to accurately report reliable grant program results.
This creates a risk to the integrity and value of the EPA's reported P2
achievements and weakens confidence that the agency's pollution prevention
goals have been achieved as represented.
Guidance and Controls Do Not Ensure Consistent and Accurate
Reporting of State P2 Program Results
We found inconsistencies with the agency's reporting of results generated from
state P2 leadership programs and state P2 award programs. In addition to
providing technical assistance to businesses, some states operate P2 award
programs and state leadership programs. Typically, significant results are reported
by these types of state programs relative to technical assistance programs.
According to the EPA, because the results from these types of state programs are
large and the EPA's involvement is less as compared to the traditional technical
assistance programs, the measurement guidance instructs the regions to not report
100 percent of the results but rather count a percentage. However, we found the
lack of specificity in the measurement guidance led to inconsistencies in reporting
P2 grant results. For example, we found inconsistencies in the percentage of
results reported by the EPA for each region reviewed. According to headquarters
staff, regional staff turnover also led to the inconsistencies in reporting. Improved
guidance would facilitate more accurate and consistently reported P2 grant results
derived from these state P2 programs.
Reporting of Results From State P2 Environmental Leadership
Programs Inconsistent
We found inconsistencies with the agency's reporting of results generated
from some state P2 programs. P2 measurement guidance instructs the regions
8	The regions solicit requests for proposals annually and have established controls to rate and rank submitted
proposals. A factor used in the selection process is the alignment of the proposed activity to the EPA's P2 goals.
Further, the regions' P2 coordinators receive and maintain interim and final reports where results from funded
activities are recorded to support the EPA's P2 goal achievements.
9	EPA Regional P2 Measurement Guidance, October 19, 2012.
15-P-0276
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to claim only a percentage of the results reported by state P2 leadership
programs rather than 100 percent of the results. According to the measurement
guidance the reason to claim a portion of the percentage for state leadership
programs is because the EPA has less influence as compared to technical
assistance-type programs.10 Headquarters staff added that a reduction is also
necessary in an effort to make the percent of implementation funding and the
percent of results claimed comparable in degree. The guidance establishes that
the percentage claimed by the EPA should range between 10 and 40 percent.
The guidance states:
Choose a reporting number that is not too small and not too
big.... Report a minimum of 10% of results. Report 20, 30, or
40% if EPA's contribution is along those lines, considering
grant funding, and any other assistance through FTE, meeting
space, materials, or web resources.
We found that this measurement guidance was inadequate and was applied
arbitrarily. This guidance was inadequate because it lacked specificity, which
in part resulted in reporting variances in similar activities from state to state
and from one year to the next. For example, FY 2011 results associated with
one state P2 leadership program were reported at 10 percent, whereas in the
following fiscal year the results from the same activities were reported at
40 percent. No reason was specified for the difference and no documentation
for the percentage used was available in the file. According to headquarters
staff, the percentage used in reporting FY 2011 results was incorrect. In
addition, results from another state program activity were reported at
100 percent for the EPA, which is inconsistent with the guidance. We also
found that some regions report 100 percent of the results from these types of
P2 programs and headquarters made reductions. This inconsistent and
arbitrary application of the guidance adversely impacts the agency's ability to
accurately report reliable grant program results, which creates a risk for the
integrity of the EPA's reported P2 achievements.
Reporting Results From Government Facilities Inconsistent
Grantees report to the EPA regions P2 results reported by members of their
program. We found that some state P2 environmental leadership programs
have federal, state and local governments as members. EPA headquarters staff
stated during our review that government results should be excluded from
state results, though this was not specified to the P2 Measurement Guidance.
Additionally, according to PPA, only the cost savings to businesses should be
counted. We found confusion among some P2 program staff on whether the
results from government facilities should be included and reported by the
10 According to the measurement guidance, when considering EPA's influence regions should consider grant
funding, and any other assistance through FTE, meeting space, materials, or web resources, when deciding in the
range of 10 to 30 percent.
15-P-0276
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regions as part of the state program results. Importantly, we did not see any
evidence that results from government members were consistently being
excluded from the final reported results.
Reported P2 Grant Results Cannot Be Reconciled Between the
Regions and Headquarters
We found inconsistencies and errors in the reporting of P2 grant results for the
years we reviewed. We also found the rationale for revisions in reported results
made by headquarters were not adequately documented. Due to the reporting
errors and lack of documentation, the reported results could not be reconciled.
Accurate reporting of results will enhance credibility and reliability that P2
funded grants are contributing to the EPA's pollution prevention goals.
Reporting Errors in P2 Grant Results
We found errors in reporting grants results. In the regions we visited, we
found 58 errors out of 128 (45 percent error rate) of the FYs 2011 and 2012
performance metrics reported from the regions to headquarters. We found
various errors made by the regions when transcribing results from the grantee
final reports to the regional reported aggregate results submitted to
headquarters. For example, we found an instance where a region reported
17,000 gallons of water saved to headquarters instead of the 17,000,000
gallons as actually reported by the grantee.
P2 Grant Results Subject to Multiple Headquarter Revisions
We found results reported to headquarters by the regions were subject to
significant revisions. According to headquarters staff, they conduct a quality
review of the overall results submitted by the regions and make changes when
deemed necessary. Headquarters conducted an extensive review of the
FY 2011 P2 grants' reported results, which led to substantial changes. As
noted in Table 2, there were significant differences between the FY 2011
results reported by the regions and the results headquarters posted on the
agency's website in 2013. According to headquarters staff, changes are made
to the regional-reported results to address methodological issues or errors
identified during their review.
Table 2: Revisions made to FY 2011 results reported by regions
Results reported
Carbon dioxide
reduced
(MTC02e)
Hazardous
material reduced
(pounds)
Water saved
(gallons)
Dollars
saved
Submitted by Regions
2,203,893
7,668,498
1,051,701,246
$208,173,723
Headquarters Reported in 1/2013
916,335
32,858,266
982,792,208
$88,341,374
Differences in Reported Results
-1,287,558
+25,189,728
-68,909,038
-119,832,349
Source: OIG based on EPA-reported P2 grant results.
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The Office of Pollution Prevention and Toxics has been developing a new
database, called "P2 GrantsPlus," that is intended to provide a system to
maintain and track P2 grant activities from planning to final results.
According to P2 staff, this new database will make P2 grant results traceable
back to the supporting documents and allow for documentation of changes
made in computing the final results.
We also found that the EPA's FY 2011 P2 results reported on the EPA's
public website in January 2013 were later revised. According to headquarters
staff, the revised P2 grant results were reflected in the FY 2015 budget
documents. However, the revised performance results were not posted on the
agency's website until March 2015. Therefore, the results reported to the
public on the webpage were incorrect and there was no notation on the
website reflecting the impending revision. Three of the revisions were
significant:
1)	The EPA's results for hazardous materials reduced was reduced by
almost 25 million pounds.
2)	The EPA's results for water saved was increased by over 16.5 million
gallons.
3)	The EPA's results for cash saved by businesses was reduced by more
than $5 million.
The need for multiple revisions further illustrates the need for improved
controls to ensure the accuracy of reports and avoid EPA misrepresentation of
its achievements when reporting to the public.
Recent Agency Actions Prompted by OIG Work
On April 28, 2015, the agency revised its measurement guidance addressing
issues noted during this review.11 The new measurement guidance:
•	Establishes that the percentage claimed by the EPA should range between
10 and 30 percent. Further, to address the inconsistencies we noted from
year to year, the revised guidance requires regions to now provide an
explanation if the percentage reported from one year to the next increases.
•	Provides details pertaining to the "right quantity and type of results to
report." Under this new guidance, regions are advised to not report results
from federal entities, institutions, or state and local entities if State
Leadership Programs are funded by P2 grants. It further added that P2
grants are to be just for P2 assistance to businesses.
11 US-EPA Regional P2 Measurement Guidance: Collecting and Reporting Results, April 28, 2015.
15-P-0276
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Conclusions
The EPA is unable to determine the extent to which P2 grants achieve pollution
prevention goals because the agency lacks controls to ensure that results from
grants are reported accurately and consistently across regions. Some reported
results were inaccurate based on extensive revisions EPA made and we
discovered during our review. These inaccuracies and lack of management
controls weaken confidence that the agency's pollution prevention goals have
been achieved as represented. Clear and consistent management controls that
ensure only eligible and accurate results are reported will enable the EPA to
demonstrate the extent that P2 grants are contributing to achieving its P2 goals.
Recommendations
We recommend that the Assistant Administrator for Chemical Safety and
Pollution Prevention:
1.	Implement the P2 GrantsPlus database to begin the process for enhancing
the reporting and recording of its P2 grants.
2.	Develop and implement controls to ensure accurate and consistent
reporting of regional results to headquarters and documentation of
revisions made by headquarters.
Agency Comments and OIG Evaluation
The agency agreed with our findings and recommendations, and provided
corrective actions and estimated completion dates that meet the intent of the
recommendations. Based on the agency's written response, the recommendations
are resolved and open with corrective actions ongoing. No further response to this
report is required. The agency's detailed response is in Appendix B. The agency
also provided a technical comment on the draft report, which we incorporated into
our report as appropriate.
15-P-0276
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Status of Recommendations and
Potential Monetary Benefits
RECOMMENDATIONS
POTENTIAL MONETARY
BENEFITS (In $000s)
Rec.
No.
No.
Subject
Status1
Action Official
10 Implement the P2 GrantsPlus database to begin
the process for enhancing the reporting and
recording of its P2 grants.
10 Develop and implement controls to ensure
accurate and consistent reporting of regional
results to headquarters and documentation of
revisions made by headquarters.
Planned
Completion
Date
Assistant Administrator for 9/30/15
Chemical Safety and
Pollution Prevention
Assistant Administrator for 10/31/15
Chemical Safety and
Pollution Prevention
Claimed
Amount
Ag reed-To
Amount
1 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's Response to Draft Report
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
July 17,2015
MEMORANDUM
SUBJECT: Response to Office of Inspector General Draft Report No. OPE-FY 15-0002
"EPA Needs Accurate Data on Results of Pollution Prevention Grants to
Maintain Program and Measure Effectiveness of Grants," dated June 17, 2015
Thank you for the opportunity to respond to the issues and recommendations in the subject report.
This memorandum provides the Agency's response to the Office of Inspector General (OIG)
recommendations and identifies corrective actions the Agency will be taking in response.
One item in the draft OIG report pertains to how EPA reports state pollution prevention (P2)
results. We are proposing a technical correction to the OIG report to clarify the relationship
between types of state programs and the P2 Grant Measurement Guidance (Attachment A).
The report contains a total of two recommendations. Below we list each recommendation and the
Agency response, including timeframes for implementation.
Recommendation 1. Implement the P2 GrantsPlus database to begin the process for enhancing the
reporting and recording of its P2 grants.
Response: EPA's Office of Chemical Safety and Pollution Prevention (OCSPP) agrees.
OCSPP will implement the P2 GrantsPlus database to begin the process for enhancing the
reporting and recording of its P2 grants.
Planned Corrective Actions and timeline for completion:
1. May, 2015 (Completed): OCSPP launched P2 GrantsPlus on the EPA staging server,
conducted a P2 GrantsPlus webinar for the Regions, and distributed a user's manual.
FROM: James J. Jones
Assistant Administrator for Chemical Safety and Pollution Prevention
TO:
Arthur A. Elkins, Jr.
Inspector General
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2. September, 2015: OCSPP will fully deploy P2 GrantsPlus with an enhanced output
measurement feature added to the May staging server version.
Recommendation 2. Develop and implement controls to ensure accurate and consistent reporting
of regional results to headquarters and documentation of revisions made by headquarters.
Response: OCSPP agrees. OCSPP will develop and implement four additional controls for
accurate and consistent reporting of regional results to headquarters and documentation of
revisions made by headquarters.
Planned Corrective Actions and timeline for completion:
1.	September, 2015: OCSPP will fully deploy the P2 GrantsPlus Database. The P2
GrantsPlus database, which was launched in May 2015, has high-level controls for
accuracy and consistency of reporting. In the system, regions must describe how their
grantees respond to requirements for explaining results at the facility level. This
provides the basis for headquarters and regions to assess the eligibility and accuracy of
results reported. Every entry is readable by headquarters and all ten regions, including
uploaded grant reports, notes on follow-up conversations, and documentation of
revisions made by headquarters.
2.	October, 2015: OCSPP will distribute a tip sheet or guidance to the regions on how to
minimize data entry errors in reporting.
3.	May, 2015 (Completed): OCSPP will continue to require grantees - through the
Request for Proposals (RFP) and subsequent Grant Terms and Conditions - to explain
facility-level results. These requirements are controls that complement P2 GrantsPlus
controls. On January 23, 2014 and May 14, 2015, OCSPP published this facility level
reporting requirement in the respective RFPs. In June of each year, OCSPP distributes
the related Grant Term and Condition to the regions, and will continue adding this
requirement to future RFPs.
4.	April, 2015 (Completed): OCSPP issued the 2016-2017 National Program Guidance
for the Pollution Prevention Program. This guidance is a control that clarifies that,
under P2 grants, governmental results cannot be counted. On April 29, 2015, OCSPP
published its National Program Guidance on the web, which is to be followed by
regions and grantees. In it, OCSPP states on page 23 that, "Under P2 Categorical
grants, only results from businesses can be counted. Under Source Reduction
Assistance (SRA) grants and non-grant P2 projects, results can also be counted from
institutions and government agencies."
See:http://www2.epa.gov/planandbudget/final-fy-2016-2017-office-chemical-safety-
and-pollution-prevention-ocspp-npm-guidance
CONTACT INFORMATION
If you have any questions or need further information about this response, please contact Janet L.
Weiner, OCSPP's Audit Liaison, at (202) 564-2309.
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Appendix B
Distribution
Office of the Administrator
Assistant Administrator for Chemical Safety and Pollution Prevention
Agency Follow-Up Official (the CFO)
Agency Follow-Up Coordinator
General Counsel
Associate Administrator for Congressional and Intergovernmental Relations
Associate Administrator for Public Affairs
Regional Administrator, Region 1
Regional Administrator, Region 3
Regional Administrator, Region 4
Deputy Assistant Administrator for Chemical Safety and Pollution Prevention
Audit Follow-Up Coordinator, Office of Chemical Safety and Pollution Prevention
Audit Follow-Up Coordinator, Region 1
Audit Follow-Up Coordinator, Region 3
Audit Follow-Up Coordinator, Region 4
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