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U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF INSPECTOR GENERAL
Green
& Healthy
Schools
The EPA Needs to Improve
Management of Its
School Environmental
Health Efforts
March 27,
Report No. 13-P-0201
2013
Scan this mobile
code to learn more
about the EPA OIG.

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Report Contributors:
Carolyn Copper
Jerri Dorsey
Jeffrey Harris
Natasha Henry
Kathryn Hess
Kalpana Ramakrishnan
Thane Thompson
Abbreviations
AHERA
Asbestos Hazard Emergency Response Act
CGHS
Clean Green and Healthy Schools
EISA
Energy Independence and Security Act
EPA
U. S. Environmental Protection Agency
FY
Fiscal Year
IAQ
Indoor Air Quality
IPM
Integrated Pest Management
OCHP
Office of Children's Health Protection
OECA
Office of Enforcement and Compliance Assistance
OIG
Office of the Inspector General
Cover photo: Image is from the EPA's Healthy School Environments website (EPA photo).
Hotline
To report fraud, waste, or abuse, contact us through one of the following methods:
e-mail:	OIG Hotline@epa.gov	write: EPA Inspector General Hotline
phone:	1-888-546-8740	1200 Pennsylvania Avenue, NW
fax:	202-566-2599	Mailcode 2431T
online:	http://www.epa.gov/oiq/hotline.htm	Washington, DC 20460

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U.S. Environmental Protection Agency
Office of Inspector General
At a Glance
13-P-0201
March 27, 2013
Why We Did This Review
The Office of Inspector General
of the U.S. Environmental
Protection Agency conducted this
evaluation to determine how
effectively the EPA ensures the
environment in schools is healthy
for children. Specifically, we
looked at how the EPA
implements its school
environmental health programs to
protect children's health.
More than 60 million students
and teachers attend over 130,000
public and private schools in the
United States. Poor
environmental conditions in
schools can inhibit learning,
increase absenteeism, and pose
increased risks to children's
health.
In fiscal year 2011, the agency
launched the Clean Green and
Healthy Schools initiative to
support states and communities
promoting healthier school
environments. The initiative's
vision is that children "will grow,
learn and play in clean, green,
and healthy schools."
This report addresses the
following EPA Goal or
Cross-Cutting Strategy:
• Working for environmental
justice and children's health.
For further information, contact
our Office of Congressional and
Public Affairs at (202) 566-2391.
The full report is at:
www.epa.qov/oiq/reports/2013/
20130327-13-P-0201.pdf
The EPA Needs to Improve Management of Its
School Environmental Health Efforts
What We Found
The EPA established children's health as a priority. The EPA's work on
environmental health in schools includes educating school officials about
asbestos risks, developing a compliance tool for schools with drinking water
violations, and providing grants. Further, many states base their laws for indoor
air quality in schools on the EPA's work and tools.
The EPA created the Clean Green and Healthy Schools initiative to promote
healthier school environments. However, the initiative lacks necessary
management controls to ensure that the EPA provides consistent
implementation of the program across the United States. The agency recently
developed some measures for the initiative, but those measures are not
specific enough to demonstrate program outcomes. In addition, regional staff
may not be able to collect the data needed to determine how the initiative is
improving environmental health in schools.
As the EPA works to improve initiative management, the agency needs to take
into account the impact that funding reductions may have on its school
environmental health efforts. The EPA has reduced funding for the CGHS
initiative, as well as reduced or eliminated funding for some related school
environmental health programs. Most notably, the EPA eliminated funding for
its Indoor Air Quality Tools for Schools program, even though school personnel
nationwide use the tools. Because of funding reductions, the EPA cut the
scope of activities originally planned under the CGHS initiative, further reducing
needed services to schools.
Finally, the EPA did not meet all requirements of the Healthy High-Performance
Schools subtitle of the Energy Independence and Security Act. The agency
was nearly 3 years late issuing school environmental health guidelines for
states, which delayed assistance to the states. The EPA also did not report
annually, resulting in Congress being uninformed about delays.
Recommendations and Planned Agency Corrective Actions
The EPA should improve management controls for the CGHS initiative. This
includes better planning, measures, and data collection procedures to ensure
consistent regional implementation. The agency should also comply fully with
the Energy Independence and Security Act. Finally, the EPA should regularly
review its school environmental health programs to determine whether the
agency provides sufficient regulatory and voluntary program services to
address the risks to children's health in schools.
The agency agreed to all recommendations and provided corrective actions
and completion dates. The recommendations remain open with corrective
actions ongoing. No further response to this report is required.

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
THE INSPECTOR GENERAL
March 27, 2013
MEMORANDUM
SUBJECT: The EPA Needs to Improve Management of Its
School Environmental Health Efforts
Report No. 13-P-0201
FROM: Arthur A. Elkins Jr.
TO:	Bob Perciasepe
Deputy Administrator
Jackie Mosby, Acting Director
Office of Children's Health Protection
This is our report on the subject evaluation conducted by the Office of Inspector General of the
U.S. Environmental Protection Agency. This report describes the problems the OIG identified and
makes recommendations to address these problems. 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
You are not required to provide a written response to this final report, because you agreed to all
recommendations and provided corrective actions and completion dates that meet the intent of the
recommendations. The recommendations remain open with corrective actions ongoing.
Should you choose to provide a response to this final report, 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 have no objections to the further release of this report to the public. We will post this report to our
website at http://www.epa.gov/oig.
If you or your staff have any questions regarding this report, please contact Carolyn Copper, assistant
inspector general for the Office of Program Evaluation, at (202) 566-0829 or copper. carolyn@epa. gov;
or Jerri Dorsey, acting director for Cross Media, at (919) 541-3601 or dorsev.ierri@epa.gov.
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The EPA Needs to Improve Management of Its
School Environmental Health Efforts
13-P-0201
Table of C
Chapters
1	Introduction		1
Purpose		1
Background		1
Scope and Methodology		4
2	The EPA Should Improve Management of
School Environmental Health Efforts		6
CGHS Initiative Needs Better Planning, Implementation,
and Guidance		6
CGHS Initiative Planning Should Consider Reductions in
Related Program Funding and Priority		8
The EPA Did Not Meet All Requirements of EISA		11
Conclusion		12
Recommendations		12
Agency Response and OIG Evaluation		13
Status of Recommendations and Potential Monetary Benefits		14
Appendices
A Agency Response to Draft Report	 15
B Distribution	 19

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Chapter 1
Introduction
Purpose
The Office of Inspector General of the U.S. Environmental Protection Agency
sought to determine how effectively the EPA ensures the environment in existing
schools is healthy for children. Specifically, we focused on whether the EPA was
effectively implementing programs directed at existing schools, and whether the
Office of Children's Health had created enough program criteria to guide regional
implementation. Further, we determined whether the EPA has data to measure
program effectiveness, and how other programs are filling the gaps left by the
defunding of some EPA Schools Programs over the last 5 years.
Background
Children are more vulnerable to harmful environmental exposures, because their
bodies are still developing and they eat, drink, and breathe more in proportion to
their body size. Children's behavior also exposes them to potential hazards from
chemicals, pesticides, and organisms.
Children's health has been a federal priority since 1997 when President Clinton
signed Executive Order 13045. This order requires federal agencies to make the
identification and assessment of children's environmental health and safety risks a
high priority. This order further requires that federal agencies ensure that policies,
programs, activities, and standards address environmental health and safety risks
to children. The EPA Administrator made leadership in children's environmental
health an agency priority. In a memorandum to the senior agency officers in
February 2010, the Administrator stated: "[W]e must ensure that children's health
protection is a driving force in our decisions." This agency priority fulfills
Executive Order 13045.
The EPA's Strategic Plan sets forth an agency commitment "to preserve the
environment for future generations and to protect human health in the places
where people live, work, learn, and play." Inclusion of where people learn in this
statement points to the key role environmental health in schools plays in
children's health.
Poor environmental conditions in schools can inhibit learning, increase
absenteeism, and pose increased risks to children's short- and long-term health.
Five days a week, over 54 million students from kindergarten through 12th grade
attend more than 130,000 public and private school facilities in the United States.
Over seven million teachers and other employees work in these schools.
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The EPA's School-Based Efforts
The EPA collaborates with others working to improve school environmental
health, including children, families, teachers, school districts, advocacy
organizations, state agencies, and other federal agencies. The EPA regulates some
hazards in schools, such as asbestos; and assists states, school districts, and
schools in addressing other unregulated hazards, such as mold. The EPA has
implemented 10 programs that specifically target environmental and health risks
in schools. The EPA features these 10 programs prominently on its "EPA Schools
Programs" website.1 For the purpose of this evaluation, we focused on the five
programs that contribute to improving environmental health for children in
existing school buildings. We describe these programs and some program results
in Table 1.
The EPA has devoted considerable resources to educating school officials about
the risks associated with asbestos and the management of those risks. The EPA
also developed a compliance tool for schools with persistent drinking water
violations. In 33 states and the District of Columbia, the EPA's work on indoor air
quality serves as the basis for laws requiring schools to develop and implement
indoor air quality programs. Six of these laws specifically cite the EPA's Indoor
Air Quality Tools for Schools. Finally, the EPA periodically awarded grants for
work aimed at improving school environmental health in areas such as indoor air
quality, integrated pest management, chemical cleanout, and state environmental
health programs.
The OCHP within the Administrator's office is coordinating activities across
agency programs and regions to enhance delivery of tools to promote healthy
school environments. Most recently, in an effort to address environmental health
in schools, the EPA requested funds for fiscal year 2011 to launch the Clean
Green and Healthy Schools initiative to support states and communities
promoting healthier school environments. OCHP formed the cross-agency School
Coordination Group to collaborate and coordinate the CGHS initiative efforts.
The EPA's vision for the initiative is that "children, regardless of age, race,
economic status, or ethnicity will grow, learn and play in clean, green, and
healthy schools."
To support this vision, the EPA will:
1.	Work to increase understanding of chemical, biological, and physical
hazards in schools, and encourage the use of resources to create healthier
learning environments.
2.	Build internal and external partnerships to support the development of
clean, green, and healthy schools.
1 Healthy School Environments at http://www.epa.gov/schools/programs.html.
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Table 1: EPA Environmental Health Programs Serving Existing Schools
Program
Description

Asbestos in
Schools
The Asbestos Hazard Emergency Response Act became law in October
1986 as part of the Toxic Substances Control Act. Under AHERA and its
regulations, schools are required to determine if their facilities have
asbestos, develop a plan to remove or manage it, and then conduct ongoing
management and risk assessment reviews if they decide to manage the
asbestos in place. The EPA has conducted numerous inspections of schools
and provided compliance assistance to help schools meet the requirements
of the AHERA regulations.
Drinking Water in
Schools
Under the Safe Drinking Water Act, the water supplier is responsible for the
quality of the drinking water. Fewer than six percent of schools in the United
States operate their own drinking water systems. The EPA's Office of Water
and Office of Enforcement and Compliance Assistance worked together to
identify schools that were out of compliance and developed a compliance
tool for schools with persistent drinking water violations. Other efforts in
schools to ensure safety of drinking water, such as testing for lead and other
contaminants at drinking water faucets, are voluntary. The EPA provides
information that assists all schools in these voluntary efforts.
Indoor Air Quality
Tools for Schools
Program
The EPA provided information and outreach to states and school districts on
indoor air quality issues within schools for many years. Notably, the EPA
created the Indoor Air Quality Tools for Schools and the Healthy School
Environmental Assessment Tool. Because of these efforts, 33 States and the
District of Columbia have established their own laws requiring that schools
develop and implement indoor air quality programs.
Integrated Pest
Management in
Schools
Integrated Pest Management helps schools manage pests economically with
the least possible hazard to health, property, and the environment. This effort
includes reducing exposure to the pesticides, herbicides, and other
chemicals used in schools and on school grounds. In November 2011, the
EPA allocated additional funds to school IPM activities; created 10 regional
school IPM positions; and initiated the establishment of a Center of Expertise
in school IPM.
Schools
Chemical
Cleanout
Campaign
The EPA's Schools Chemical Cleanout Campaign aimed to ensure that
schools are free from hazards associated with mismanaged chemicals. The
EPA provided schools information and tools to manage chemicals
responsibly, and awarded grants to clean out old laboratory chemicals.
Source: OIG analysis of EPA and Environmental Law Institute publications and material.
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The Energy Independence and Security Act
The Healthy High-Performance Schools subtitle of Title IV of the Energy
Independence and Security Act of December 2007 tasked the EPA with four
actions to improve school environmental health. The agency has completed three
of the four actions. In October 2011, the EPA issued guidance on school siting.
In September 2012, the EPA awarded five grants to states to provide technical
assistance to schools and to develop and implement state school environmental
health programs. In October 2012, the EPA issued guidelines for voluntary use by
states in developing and implementing an environmental health program for
schools. Finally, EISA required the EPA to report annually to Congress on all
activities carried out under the Healthy High-Performance Schools subtitle. As of
March 26, 2013, EPA has not reported to Congress.
Scope and Methodology
We conducted this evaluation from January 2012 to December 2012, in
accordance with generally accepted government auditing standards. Those
standards require that we plan and perform the evaluation to obtain sufficient,
appropriate evidence to provide a reasonable basis for our findings and
conclusions based on our objectives. We believe that the evidence obtained
provides a reasonable basis for the results reported based upon our objectives.
The scope of our evaluation was limited to the EPA's programs that provide
environmental health services to existing schools. We reviewed and assessed the
scope, and achieved or anticipated outcomes for the 10 EPA Schools Programs
listed on the EPA's healthy school environments website. We determined that five
programs fell within our scope:
•	Asbestos in Schools.
•	Drinking Water in Schools.
•	Indoor Air Quality Tools for Schools.
•	Integrated Pest Management in Schools.
•	Schools Chemical Cleanout Campaign.
We did not review programs that address the design of new buildings to eliminate
potential hazards, the siting of new schools to contribute to community smart
growth efforts, the reduction of emissions from school buses, energy
consumption, or educating students about being safe in the sun.
The new CGHS initiative fell within our scope. In addition, we determined that
three provisions of the EISA Healthy High-Performance Schools subtitle fell
within our scope:
1. Awarding grants to states to provide technical assistance to schools, and
develop and implement state school environmental health programs.
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2.	Issuing guidelines for voluntary use by states in developing and
implementing an environmental health program for schools.
3.	Reporting annually to Congress on all activities carried out under the
Healthy High-Performance Schools subtitle.
We reviewed pertinent documents and interviewed officers, managers, and staff
in OCHP and relevant EPA program offices. We received responses from all 10
EPA regions to a set of questions on school programs. We also received
information from officers of three organizations that work with the EPA and
others to improve school environmental health:
•	IPM Institute of North America.
•	Healthy Schools Network.
•	American Association of School Administrators.
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Chapter 2
The EPA Should Improve Management of
School Environmental Health Efforts
The EPA's current school environmental health efforts need management and
planning improvements to meet the agency priority of protecting children in the
places where they learn. The new CGHS initiative lacks management controls and
guidance necessary to ensure consistent implementation and data collection
requirements to demonstrate outcomes. Further, the initiative's new vision and
measures documents do not ask regions to address how they will achieve results
after the EPA reduced or eliminated funding for several existing school programs.
Finally, the EPA was nearly 3 years late issuing school environmental health
guidelines for voluntary use by states, and has not reported annually to Congress
as required by EISA. Without improving the management and planning of its
school environmental health efforts, the EPA is at risk of not executing these
efforts in the most effective way.
CGHS Initiative Needs Better Planning, Implementation,
and Guidance
The EPA created the CGHS initiative to build partnerships around healthy
schools, increase understanding of hazards in schools, and encourage the use of
resources to create healthier schools. We found that the initiative lacks necessary
management controls, and the EPA has not yet developed guidelines and
expectations that are specific enough to ensure consistent implementation.
The EPA's vision and measures documents outline broad expectations for the
initiative. However, the EPA has not required regions to develop implementation
plans, establish specific outcomes, or identify how they will collect data to
document those accomplishments. Without specific implementation plans and
measures, OCHP and the regions are unlikely to achieve results. Without specific
data collection requirements, OCHP and regions are unlikely to identify, collect,
and analyze the data needed to determine the initiative's effectiveness.
Initiative Lacks Guidelines for Planning, Implementation,
and Oversight
The CGHS initiative does not have specific implementation guidelines.
The School Coordination Group, composed of representatives from OCHP, the
regions, and EPA program offices, developed a Vision, Goals, Objectives, and
Activities or "Vision" document for the initiative. The Vision document outlines
an overall vision, general programmatic goals, and broad activities for FYs 2013
and 2014. However, this Vision document does not take the place of specific
implementation guidelines. Each region's program should meet the needs of the
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states and school districts in their region; however, a national program also should
have a core set of criteria that each region must meet.
The EPA also developed the CGHS Regional FY 2013 Developmental Measures
or "Regional Measures" document that seemed to establish a core criterion for the
initiative:
Improve the health of school and child care environments by supporting
state, tribal and local efforts to address environmental health issues in
schools and child care centers, with a focus on the poorest performing
schools, under served communities and tribes.
This criterion reiterates a sub-objective in OCHP's strategic plan. However, the
EPA did not include this criterion in its Vision document. The EPA lays out
headquarters and regional output measures in the Regional Measures document
that tabulate all school activities. The Regional Measures document does not
require separate reporting of the focus activities. Without clear criteria and
expectations, the EPA lacks assurance that headquarters and regions will focus
their activities on the poorest performing schools, underserved communities, and
tribes. Further, OCHP has not posted basic initiative information on its healthy
schools website. In our opinion, this lack of information creates challenges for
consistently communicating with both internal and external partners. Updating the
website would be an effective method of communicating the initiative's vision,
goals, and plans, and should be part of OCHP's implementation guidelines.
The Vision document does not require regions to develop region-specific
implementation plans, identify specific outreach targets, or develop specific
output and outcome levels. The EPA did not finalize the Vision document until
October 9, 2012. Prior to this date, regional staff were unsure what the EPA
expected them to achieve through the program. Some regions were reluctant to
move forward in establishing their specific regional plans until the EPA finalized
the national guidelines. However, according to the EPA's Key Performance
Indicators for FY 2012, the EPA was to establish implementation plans for
OCHP and the regions by February 29, 2012.
The CGHS initiative lacks management controls to achieve desired outcomes.
Current EPA guidance does not require regions to develop oversight processes,
determine what services are needed, or determine if its services are meeting those
needs. Furthermore, the initiative does not have oversight, evaluation, or
assessment criteria. Without criteria, the EPA cannot improve the program or
respond to changing customer needs. Regions also are not required to gather and
disseminate best management practices, although OCHP developed the School
Coordination Group to share this information informally. While the EPA recently
developed program measures, the lack of planning and implementation
requirements prevents the EPA from determining what outcomes it has achieved.
The EPA also cannot report which schools have reduced environmental risks to
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their students. As a result, the effectiveness of the CGHS initiative will remain
unknown.
CGHS Initiative Lacks Specific Outcome Measures
The EPA completed its Regional Measures document on October 4, 2012.
Regions will report the number of school decision-makers who receive
information or participate in capacity building exercises. Regions plan to report
the number of schools and school districts that have taken action to become
cleaner, greener, and healthier. In addition, regions intend to track the number of
external outreach forums or activities hosted or attended to promote the CGHS
initiative. However, regional outcome measures are all narrative and qualitative.
As such, the CGHS initiative lacks specific outcome measures.
The Regional Measures document states that during the baseline developmental
period (FYs 2012 through 2014), the EPA will work to "craft realistic measures of
progress and effectiveness that can be used for future reporting." However, the
EPA has not established implementation guidelines that specify how these
revisions will be undertaken and what information it will use.
Before the EPA finalized the Regional Measures document, regional staff said
that even if the EPA identified specific measures, collecting the needed data
would be difficult. Regional staff said that without their own funding for data
collection, they would have to rely on the data that the schools already collect.
However, schools have very limited data collection budgets and are not always
willing to release information to the EPA. This lack of direct data collection limits
the EPA's ability to determine what effects the initiative will have. It also
prevents the EPA from knowing if the environmental health in existing schools
has improved. As a result, the EPA will face challenges in collecting data and
ensuring that the initiative's activities consistently work to improve school
environmental health for students and teachers across the United States.
CGHS Initiative Planning Should Consider Reductions
in Related Program Funding and Priority
The EPA has reduced or eliminated funding for several programs working to
improve environmental health in schools, including the new CGHS initiative and
programs that would have worked in conjunction with the initiative. Improving
environmental quality in schools is a partnership among federal, state and local
agencies, as well as with nongovernmental organizations. However, since 2008,
the EPA has cut or defunded several programs that supported those partnerships.
For example, the EPA eliminated the School Chemical Cleanout Campaign at the
beginning of FY 2008, reducing the EPA's ability to help schools manage
hazardous wastes used in science laboratories and art classrooms. Even the newly
launched school IPM program is experiencing reductions in grants. Additionally,
the EPA eliminated funding for the IAQ Tools for Schools program designed to
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improve indoor air quality, and reduced in priority another program intended to
ensure schools manage asbestos in a safe manner.
OCHP and regional staff informed us that the EPA does not intend the CGHS
initiative to take the place of the reduced and defunded school programs.
When OCHP proposed the CGHS initiative, it could not foresee the potential
programmatic and resource voids created by the EPA's most recent cuts to its
mature school-related programs. Ten years ago, the Children's Health Protection
Advisory Committee to the EPA recommended that the EPA "[ejvaluate and
document the effectiveness of existing EPA school environmental health
programs, such as IAQ Tools for Schools." The EPA needs to conduct this type of
evaluation to understand how the new initiative can improve its school
environmental health efforts. Further, as OCHP and the regions work to improve
their CGHS initiative planning, they need to take into account the impact that
programmatic cuts have had on all of the EPA's school environmental health
efforts.
The EPA Cut CGHS Initiative Funding
The EPA has reduced the funding for the CGHS initiative. OCHP requested at
least 1.1 full-time equivalent positions per region to fund regional schools
coordinators, but could only provide funding for the fourth quarter of FY 2011.
In FY 2012, funding levels fell to less than 50 percent of what OCHP initially
requested. The FY 2012 cuts also reduced headquarters staff support. OCHP
requested one position to coordinate headquarters and regional school activities
and to establish management controls, but this position was not funded. As a
result, the EPA cut the scope of activities originally planned under the initiative,
further reducing needed services to schools.
The EPA Eliminated Indoor Air Quality Tools for Schools
OCHP launched the CGHS initiative while the EPA fully funded its IAQ Tools
for Schools program. The organization officers we interviewed on indoor air
quality were concerned about the elimination in FY 2012 of IAQ Tools for
Schools and other cuts to school environmental health programs. According to
those we interviewed in and outside the EPA and the documents we reviewed,
school personnel nationwide used the IAQ Tools for Schools. The tools formed
the basis for school environmental health statutes in more than 30 states. The
EPA's IAQ Tools for Schools program also integrated well with other EPA
Schools Programs, such as school IPM. The program facilitated communication
and sharing of best practices among school districts and others working to
improve school environmental health. For example, over 2,300 teachers, school
administrators, public health professionals, and others had been educated on
school environmental health at the last five symposiums sponsored by the
program. In addition, regional staff and an organization officer we interviewed
expressed concern to us that the tools will not remain valuable assets if the EPA is
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not continuing to update them. OCHP and the regions will need to take into
account the new dormant status of IAQ Tools for Schools in their CGHS initiative
plans.
In the absence of the IAQ Tools for Schools program, the EPA's Indoor
Environments Division is working on ways to provide information and support,
and maintain communication among those working to improve indoor air quality
in schools. This effort includes the newly developed School Health and Indoor
Environments Leadership Development Summit. The EPA held the first summit
on July 12, 2012, with 72 representatives from federal agencies, school districts,
nongovernmental organizations, industry, and universities. This summit has the
potential to fill some of the programmatic void created by the loss of the annual
IAQ Tools for Schools symposium. However, the summit is too new to measure
or predict outcomes, and the EPA has not defined how the summit fits within the
CGHS initiative.
The EPA Reduced the Priority of Asbestos Inspections
The EPA reduced the priority of the Asbestos in Schools program for FY 2013. In
a March 9, 2012, memorandum, the principal deputy assistant administrator of the
OECA advised EPA regions about programs that were to have their priority and
funding reduced, including AHERA. The EPA proposed reducing AHERA
spending in order to increase support to other compliance monitoring and
enforcement priorities. The March 9, 2012, disinvestment plan proposed reducing
AHERA enforcement resources to less than a fourth of the existing level.2
Regions would still respond to situations involving egregious violations that
present significant risks to human health; however, most routine inspections
would cease.
The proposed reduction plan met with opposition from regional staff, program
offices and others. Several regional staff informed us that this reduction would
have a negative impact on their ability to keep children safe from asbestos. One
regional manager told us: "With the de-funding of the AHERA Inspection
Program, fewer schools are being inspected for compliance with the AHERA
regulations. Hence, [fewer] school children are being protected from the potential
exposure to asbestos." Another regional manager said, "The continued budget
reductions that have supported EPA's AHERA regulatory enforcement program
have had an adverse impact on the protection of children's health in schools. The
Region's field surveillance work has found that local education agencies are not
in compliance with the regulatory requirements of AHERA."
2 The full-time equivalent level for AHERA enforcement efforts in March 2012 was 5 positions, with 0.2 in
headquarters and 4.7 among the 10 regions. The proposed reduced level was 1.1 positions, with 0.1 in
headquarters and 1 among the 10 regions.
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On June 6, 2012, the principal deputy assistant administrator, OECA, issued an
update stating that, "[b]ased on regional and program input, OECA is no longer
looking for a full budget adjustment plan" for AHERA. However, the
June 6, 2012, correspondence also stated that OECA was still looking for regions
to reduce their resources where possible. According to OECA, many schools
successfully managed asbestos in place for decades. OECA explained that
AHERA was a mature program that needed fewer resources to conduct
inspections than in the past. However, the AHERA inspection is one of the few
regulatory authorities the EPA has in schools. As such, reductions in AHERA
inspections may increase overall environmental risks to children who attend
primary and secondary schools, as those inspection reductions would lead to
fewer opportunities for the EPA to be in the schools. As OECA changes
compliance assistance or enforcement priorities for schools, OCHP and the
regions may need to update their CGHS initiative plans to take into account these
changes.
The EPA Did Not Meet All Requirements of EISA
The EPA did not meet all requirements of the Healthy High-Performance Schools
subtitle of EISA. The EPA was nearly 3 years late issuing guidelines for voluntary
use by states developing and implementing a comprehensive environmental health
program for schools. EISA mandated completion of the guidelines by
December 19, 2009; however, the EPA did not issue draft guidelines until
February 27, 2012. The agency received public comments on these draft
guidelines through April 20, 2012, and published the final guidelines in
October 2012. For nearly 3 years, some regions did not begin work on state-level
school environmental health programs because they were awaiting guidance for
the programs. As a result, the EPA did not provide support to states in the
timeframe specified in EISA.
As of March 26, 2013, the EPA had made no reports to Congress on its activities
carried out under the Healthy High-Performance Schools subtitle. EISA required
that the EPA annually report to Congress on all activities carried out under the
subtitle. On March 5, 2013, OCHP submitted its draft report to the Office of
Management and Budget for review prior to issuing the report to Congress. The
EPA failed to report to Congress on its inactivity and missed deadlines in the
preceding 5 years. As a result, the EPA did not inform Congress and the public of
its inaction through the required reporting process.
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Conclusion
The EPA needs to improve program implementation planning, management, and
oversight to advance its efforts to reduce environmental health risks in schools.
Further, the EPA needs to consider the impacts of changes to its Schools
Programs, such as the elimination of IAQ Tools for Schools and the decrease in
priority of asbestos inspections, in its long-term plans for the CGHS initiative.
Finally, the EPA needs to report to Congress on its accomplishments and delays
under the Healthy High-Performance Schools subtitle of EISA. By taking these
actions, the EPA can implement effective programs that it has designed to protect
the health of children in the places where they learn.
Recommendations
To improve management of the EPA's school environmental health efforts, the
EPA Deputy Administrator should:
1.	Fulfill the requirement of EISA to report to Congress all activities carried
out under the Healthy High-Performance Schools subtitle.
The Director of the Office of Children's Health Protection should:
2.	Develop implementation guidelines and management controls that
specify how:
a.	OCHP will manage the adoption and implementation of the newly
developed CGHS Vision, Goals, Objectives and Activities
document, and the CGHS Regional FY 2013 Developmental
Measures document.
b.	OCHP will continue to craft realistic measures during
FY 2013-2014.
3.	Develop regional implementation guidelines and planning requirements
for the CGHS initiative. These guidelines should:
a.	Include requirements for each region to develop an implementation
plan that is consistent with the measures, strategies, and expected
outcomes identified in the CGHS Regional FY 2013
Developmental Measures document.
b.	Specify how CGHS initiative staff will coordinate better with
internal EPA and external partners, taking into account recent
changes in program status and funding.
c.	Specify how CGHS initiative staff will collect data, determine the
programmatic success of the initiative, and modify the program to
meet customer needs.
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4. Develop assessment criteria and conduct regular reviews of the EPA's
overall School Environmental Health programs to determine whether the
EPA is providing sufficient regulatory and voluntary program services to
address the risks to children's health in schools.
Agency Response and OIG Evaluation
We received a response from the Deputy Administrator on January 29, 2013.
After a meeting to discuss the response, we received an amended response from
the acting director for OCHP dated February 12, 2013. The agency agreed to all
four recommendations, and provided corrective actions and estimated completion
dates that meet the intent of the recommendations. The recommendations remain
open with corrective actions ongoing. No further response to this report is
required. The agency's January and February 2013 responses are included in
appendix A. We also modified the report to address appropriate technical
comments we received from the agency.
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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
Agreed-To
Amount
12 Fulfill the requirement of EISA to report to
Congress all activities carried out under the
Healthy High-Performance Schools subtitle.
12 Develop implementation guidelines and
management controls that specify how:
a.	OCHP will manage the adoption and
implementation of the newly developed
CGHS Vision, Goals, Objectives and
Activities document, and the CGHS Regional
FY 2013 Developmental Measures
document.
b.	OCHP will continue to craft realistic
measures during FY 2013-2014.
12	Develop regional implementation guidelines and
planning requirements for the CGHS initiative.
These guidelines should:
a.	Include requirements for each region to
develop an implementation plan that is
consistent with the measures, strategies, and
expected outcomes in the CGHS Regional
FY 2013 Developmental Measures
document.
b.	Specify how CGHS initiative staff will
coordinate better with internal EPA and
external partners, taking into account recent
changes in program status and funding.
c.	Specify how CGHS initiative staff will collect
data, determine the programmatic success of
the initiative, and modify the program to meet
customer needs.
13	Develop assessment criteria and conduct regular
reviews of the EPA's overall School Environmental
Health programs to determine whether the EPA is
providing sufficient regulatory and voluntary
program services to address the risks to children's
health in schools.
0 Deputy Administrator
Director, Office of
Children's Health
Protection
3/31/13
9/30/13
Director, Office of
Children's Health
Protection
9/30/13
Director, Office of
Children's Health
Protection
12/31/13
O = 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 Draft Report
January 29, 2013
SUBJECT: Response to the Office of Inspector General Draft Report No. OPE-FY12-0004
"EPA Needs to Improve Management of School Environmental Health Efforts,"
December 27, 2012
Thank you for the opportunity to respond to the issues and recommendations in the report "EPA Needs
to Improve Management of School Environmental Health Efforts." Following is a summary of the
agency's overall position, along with its position on each of the report recommendations. For those
report recommendations with which the agency agrees, we have provided high-level corrective actions
and estimated completion dates. For the report recommendations with which the agency does not agree,
we demonstrate how the recommendation has been adequately addressed. For your consideration, we
offer the technical comments attachment to supplement this response.
It is the EPA's position that, to date, the agency has met all requirements of the Healthy High-
Performance Schools Subtitle of Title IV of the Energy Independence and Security Act, with the
exception of the annual report to Congress. At the time of the Office of Inspector General audit report,
the EPA had not completed the annual report to Congress. However, the report has since been drafted,
and the Office of Children's Health Protection will actively work to expedite internal review of the
report and submit it to the Office of Management and Budget. Submission of the report to Congress will
fulfill the EPA's requirement to the Energy Independence and Security Act.
Protecting children's health and advancing environmental justice are key priorities for the EPA, and we
are committed to reducing exposures to the environmental hazards children encounter in their daily
lives. The EPA's mission to protect human health and the environment requires us to pay special
attention to the vulnerabilities of those who are disproportionately affected by health challenges,
especially our nation's children. Of particular note, the EPA's efforts toward encouraging the
establishment of healthy school environments and meeting the requirements set forth under the Healthy
High-Performance Schools Subtitle of Title IV of EISA are two critical examples of the type of work
being done across the agency to protect children's health.
The EPA considers the health of children in all actions that we undertake and will continue to coordinate
internally across our school-related programs and with other federal agencies and external partners to
implement our goals and measures in a manner that accurately reflects current resource levels.
If you have any questions or need additional information, please contact either Jackie Mosby, acting
director of the Office of Children's Health Protection, at (202) 566-0594 or mosby.jackie@epa.gov or
Margot Brown, director of the program implementation and coordination division, at (202) 566-0874 or
brown.margot@epa.gov.
FROM:
Bob Perciasepe, Deputy Administrator
TO:
Carolyn Copper, Assistant Inspector General for Program Evaluation
Attachment
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AGENCY'S RESPONSE TO REPORT RECOMMENDATIONS
Agreements
No.
Recommendation
High-Level Intended
Corrective Actions
Estimated
Completion by
Quarter and FY
1
Complete the requirement to EISA to
report to Congress on all activities carried
out under the Healthy High-Performance
Schools Subtitle
1. Work to expedite internal
review of report to
Congress and submit report
to OMB
2nd Quarter FY13
3
Develop regional implementation
guidelines and planning requirements for
the Clean Green and Healthy Schools
(CGHS) Initiative. The guidelines should:
a.	Include requirements for each
region to develop and implement a
plan that is consistent with the
measures, strategies, and expected
outcomes in the CGHS Regional
FY 2013 Developmental
Measures document
b.	Specify how the staff will better
coordinate with EPA internal and
external partners, taking into
account recent changes in
funding; and
c.	Specify how the CGHS Initiative
staff will collect data, determine
the programmatic success of the
initiative, and modify the program
to meet customer needs.
3.a. Require regions to
develop implementation
plans
4th Quarter FY13
3.b. Partner with EPA's
Office of Air and
Radiation to use the
recently formed
SHEILDS schools
stakeholder network
group to engage internal
and external partners
3rd Quarter FY13
4th Quarter FY13
3.c. Document a basic data
collection plan (process
may vary by region)
2nd Quarter FY13
4.
Develop assessment criteria and conduct
regular reviews of EPA's overall School
Environmental Health programs to
determine whether EPA is providing
sufficient regulatory and voluntary
program services to address the risks to
children's health in schools.
4.a. Assess EPA's School
Environmental Health
programs through the
existing Cross Cutting
Fundamental Strategy
review process (twice per
year)
3rd Quarter FY13
4th Quarter FY13
4.b. Assess EPA's School
Environmental Health
programs through the
OCHP Strategic Plan
(with Regional Measures)
review process (end of
the year)
1st Quarter FY14
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Disagreements
No.
Recommendation
Agency response
explanation
Proposed Alternative
2
Develop implementation guidelines and
management controls specify how:
a.	OCHP will manage the adoption and
implementation of newly developed
CGHS Vision, Goals and Objectives
(VGO) document and CGHS Regional
FY 2013 Developmental Measures
documents; and
b.	OCHP will continue to craft realistic
measures in FY 2013-2014.
2.a. OCHP developed
implementation
guidelines and
management controls
through the schools
Vision, Goals, and
Objectives (VGO)
document and the
regional measures
assessment document.
OCHP will continue
to manage the
adoption of the
schools VGO, OCHP
Strategic Plan and
Regional Measures
through monthly
Schools Coordinating
Group (SCG) and
Regional Schools
Coordinators
meetings.
OCHP in consultation
with the SCG and the
Regions should be
granted the
opportunity to
implement the VGO
and the regional
"realistic" measures
that reflect available
resources made to the
CGHS initiative at
both the national and
regional level.
2.b. OCHP Schools
Coordinator will
continue to work with
Regional Schools
Coordinators to
implement adoption
of realistic measures
for FY 14
A change should be
made in the report
which states "OCHP
will work with
regions to develop
realistic measures
reflective of regional
priorities and
resources"
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February 12, 2013
SUBJECT: Amendment to the Response to the Office of Inspector General Draft Report No. OPE-FY12-0004
"EPA Needs to Improve Management of School Environmental Health Efforts", December 27,
2012
FROM:	Jacqueline E. Mosby, MPH
Acting Director, Office of Children's Health
TO:	Carolyn Copper
Assistant Inspector General, Office of Program Evaluation
Thank you for the opportunity to discuss the issues and recommendations in the report "EPA Needs to Improve
Management of School Environmental Health Efforts" on February 5, 2013. We have reconsidered our response to
include the following amendment.
Agreement
No.
Recommendation
High-Level Intended Corrective
Actions
Estimated
Completion by
Quarter and FY
2
Develop implementation guidelines and
management controls that specify how:
a.	OCHP will manage the adoption and
implementation of newly developed
CGHS Vision, Goals and Objectives
(VGO) document and CGHS Regional
FY 2013 Developmental Measures
documents; and
b.	OCHP will continue to craft realistic
measures in FY 2013-2014.
2.a. OCHP will develop an
implementation plan to
manage the adoption of the
VGO and CGHS Regional
FY 13 Developmental
Measures.
3rd Quarter FY13
2.b. OCHP Schools Coordinator
will continue to work with
Regional Schools
Coordinator to implement
adoption of realistic
measures for FY 14.
4th Quarter FY13
CONTACT INFORMATION
If you have any questions regarding this response, please contact Khesha Reed, Associate Director of the of the
Office of Children's Health Protection on (202) 566-0594 or Margot Brown, Director of the Program
Implementation and Coordination Division (202)566-0874.
cc: Margot Brown, Office of Children's Health Protection
Khesha Reed, Office of Children's Health Protection
Patricia Gilchriest, Office of Executive Services
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Distribution
Office of the Administrator
Deputy Administrator
Director, Office of Children's Health Protection
Agency Follow-Up Official (the CFO)
Agency Follow-Up Coordinator
General Counsel
Associate Administrator for Congressional and Intergovernmental Relations
Associate Administrator for External Affairs and Environmental Education
Director, Office of Regional Operations
Regional Administrators, Regions 1-10
Office of the Administrator, Audit Follow-Up Coordinator
Regional Audit Follow-Up Coordinators, Regions 1-10
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