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* i-i	U.S. Environmental Protection Agency	13-P-0178
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	 \ Office of Inspector General
At a Glance
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Why We Did This Review
We conducted this review to
determine whether the U.S.
Environmental Protection
Agency (EPA) has adequate
management controls for
ensuring the effectiveness of its
Clean Air Act Section 112(r)
risk management program
(RMProgram) inspections.
Congress enacted the
RMProgram to reduce the risk
of airborne chemical releases
that could harm the public and
lessen the impact of releases
that do occur. Regulated
substances include 77 toxic
chemicals that could cause
death or serious health effects
from short-term exposures and
63 flammable substances.
Properly performed by trained,
knowledgeable inspectors,
inspections help ensure that
facilities comply with
RMProgram requirements.
EPA is responsible for
assessing compliance at over
86 percent of RMProgram
facilities nationwide.
This report addresses the
following EPA Goals or
Cross-Cutting Strategies:
	Enforcing environmental laws.
	Cleaning up communities and
advancing sustainable
For further information, contact
our Office of Congressional and
Public Affairs at (202) 566-2391.
The full report is at:
Improvements Needed in EPA Training and Oversight
for Risk Management Program Inspections
What We Found
EPA's management controls for ensuring inspector training and inspection
quality provide limited assurance of the effectiveness of its RMProgram
inspections. Proper training helps inspectors conduct quality inspections.
However, 15 of the 45 RMProgram inspectors nationwide received inspector
credentials without documentation indicating that they met minimum training
requirements. Further, six of the 12 supervisors did not meet minimum training
requirements. EPA's management controls did not detect or prevent the cases
of missed or undocumented training. Weaknesses in controls included
limitations in training tracking systems and a lack of procedures to ensure that
supervisors met their training requirements. Also, contracts and cooperative
agreements for inspection services did not include training requirements.
EPA can strengthen its RMProgram inspection guidance and oversight to
increase assurance that inspectors conduct effective inspections. EPA
guidance did not establish minimum guidelines for the scope of inspections.
Further, EPA did not have a process to monitor the quality of inspections.
Generally, inspection reports did not explain the extent to which the inspectors
reviewed specific elements of a covered process to determine compliance.
Also, our observations of two inspections indicated that procedures to verify the
facilities' RMProgram activities were limited.
An effective inspection program that includes properly trained personnel,
guidance, and oversight helps ensure compliance with program regulations,
thus decreasing the risk of airborne releases of chemicals that could harm the
Recommendations and Agency Corrective Actions
We recommend that EPA strengthen its management controls to ensure that
inspectors and supervisors meet minimum training requirements. Also, EPA
should strengthen guidance to include minimum inspection scope for
RMProgram facilities. Further, EPA should develop minimum inspection
reporting requirements and a monitoring program to assess the quality of
inspections. EPA generally concurred with our draft report's recommendations,
and has already initiated corrective actions in some cases. We consider five
recommendations open and one recommendation closed. The Agency's
response met the intent of the remaining recommendations, but the
recommendations remained unresolved pending receipt of a formal corrective
action plan with milestone dates and responsible party/office.
Noteworthy Achievements
EPA has made efforts to enhance the quality of RMProgram inspections.
For example, EPA provided advanced training courses for inspectors in 2010,
2011, and March 2012. According to EPA, it also provided the training in
August, October, and November 2012. EPA also conducted an internal
assessment of the quality of inspection reports across all 10 regions in 2011.