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U.S. Environmental Protection Agency	13-p-0363
f .JfcJL \ Office of Inspector General	August 28,2013
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^ At a Glance
Why We Did This Review
In response to a hotline
complaint, we conducted an
audit of the U.S. Environmental
Protection Agency's acquisition
of chemical fume hood
retrofitting and testing
contracts. Laboratory fume
hoods minimize chemical
exposure to laboratory workers.
The fume hoods are
considered the primary means
of protection from inhalation of
hazardous vapors, mists and
particulate matter. The
objectives of our audit were to
answer the following questions:
1.	Is the EPA complying with
applicable procurement
regulations and guidance
regarding its purchases of
chemical fume hood retrofit
kits and procurement of fume
hood testing contracts?
2.	Do the chemical fume hood
retrofit kits in question meet
applicable safety standards
and codes?
This report addresses the
following EPA Goals or
Cross-Cutting Strategies:
•	Ensuring the Safety of
Chemicals and Preventing
Pollution.
•	Strengthening EPA's
workforce and capabilities.
For further information, contact
our Office of Congressional and
Public Affairs at (202) 566-2391.
The full report is at:
www.epa.aov/oia/reports/2013/
20130828-13-P-0363.pdf
Chemical Fume Hood Testing Improvements Needed
to Reduce Health and Safety Risk to EPA Employees
What We Found
We found that the EPA complied with applicable regulations and guidance in
procuring both the chemical fume hood retrofit kits and fume hood testing
contracts. The EPA awarded both contracts using competition as opposed to
using sole source procurement contracting methods. However, the same
subcontractor, operating under the same prime contractor, is performing both the
retrofitting of the chemical fume hoods and the annual testing of the hoods, which
presents a potential conflict of interest. The agency already completed corrective
action in response to our preliminary recommendation for this finding.
In addition, our technical expert's review of a sample of testing results for the
chemical fume hoods raises numerous concerns with the way the testing was
performed at the EPA's Research Triangle Park laboratories. The subcontractor
rated the hoods as pass:
•	When not all of the EPA requirements were met.
•	When controllers or monitors were not functional.
•	When the testing results did not include all required documentation.
The agency's 2009 testing protocol spells out the criteria for testing and
evaluating the performance of fume hoods at the EPA's laboratories, and would
also be applicable to fume hood retrofitting. The EPA relied on the prime
contractor to ensure the subcontractor's fume hood testing met all requirements,
and did not retest any of the hoods, without a user's specific report of a problem.
As a result, the EPA has limited assurance as to the safety of the chemical fume
hoods, and there is a risk to the health and safety of the laboratory workers.
Recommendations and Planned Agency Corrective Actions
We recommend that the director, National Exposure Research Laboratory,
require the Research Triangle Park Safety, Health and Environmental
Management Office to:
•	Increase oversight and analysis of contractor testing results.
•	Ensure that when a monitor is reported as not functioning or inaccurate it is
timely repaired or replaced.
•	Establish a practice of retesting a sample of the chemical fume hoods
annually to verify the subcontractor's testing results.
•	Work to revise and update the EPA's 2009 testing protocol criteria.
The agency agreed to take corrective action for all four recommendations, and
provided expected completion dates. The agency's proposed corrective actions
and planned completion dates meet the intent of the recommendations.

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