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U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF INSPECTOR GENERAL
Environmental Job Training
Program Implemented Well,
But Focus Needed on
Possible Duplication With
Other EPA Programs
Report No, 12-P-0843
September 21, 2012
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Report Contributors:	Carolyn Copper
Chad Kincheloe
Jenny Drzewiecki
Barry Parker
Naomi Rowden
Abbreviations
EPA	U.S. Environmental Protection Agency
EWDJT	Environmental Workforce Development and Job Training
FY	Fiscal Year
GAO	U.S. Government Accountability Office
OIG	Office of Inspector General
OSWER	Office of Solid Waste and Emergency Response
SuperJTI	Superfund Job Training Initiative
Cover photo: Students in Richmond, California's, Job Training Program. (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	Mail code 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
12-P-0843
September 21, 2012
Why We Did This Review
We conducted this review to
determine whether the U.S.
Environmental Protection
Agency's (EPA's) Environmental
Workforce Development and Job
Training (Environmental Job
Training) program is addressing its
program goals and whether
duplications may occur with other
EPA job training programs. The
broad goals of the Environmental
Job Training program are to recruit
and teach individuals from solid
and hazardous waste-impacted
communities the skills needed to
secure employment in the
environmental field. Recruitment
focuses on low-income, minority,
unemployed, and under-employed
people. Training focuses on
assessment and cleanup of
contaminated sites, health and
safety, and other environmental
skills. In fiscal year 2011, the first
year of the program, EPA awarded
22 job-training grants collectively
valued at more than $6.5 million.
This report addresses the
following EPA Goal or
Cross-Cutting Strategy:
• Cleaning up communities
and advancing sustainable
development
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/2012/
20120921-12-P-0843.pdf
Environmental Job Training Program
impiemented Well, But Focus Needed on
Possible Duplication With Other EPA Programs
What We Found
EPA effectively established and adhered to competitive criteria that resulted in
the selection of job training proposals that addressed the broad goals of the
Environmental Job Training program. However, EPA did not have internal
controls to identify and prevent duplication with other EPA job training programs.
Consequently, there is some risk of duplication in EPA awards for job training
programs. Other EPA programs that could possibly duplicate Environmental Job
Training activities include the:
•	Superfund Job Training Initiative (SuperJTI) job readiness program
•	Surveys, Studies, Investigations, Training and Special Purpose Activities
Relating to Environmental Justice grant program
•	Environmental Justice Small Grant Program
EPA recognizes the need to identify possible duplication. In fiscal year 2012,
EPA added a requirement to its Environmental Job Training grant application for
applicants to demonstrate that their proposed project will complement, but not
duplicate, other federally funded environmental job training programs. However,
assigning a determination of duplication to an applicant may be an ineffective
internal control unless EPA has assurance that applicants possess the necessary
knowledge and skills to perform the duplication determination.
Effective internal controls should identify all EPA job training programs with
similar goals and include measurable individual program contributions or
outcomes to meet these goals. This would provide a basis for integrating
potentially duplicative, overlapping, or complementary job training programs.
Recommendation and Planned Agency Corrective Action
We recommend that the Assistant Administrator for Solid Waste and Emergency
Response establish internal controls for coordination with other EPA-funded job
training programs to prevent duplication of effort and spending. The Agency
agreed with the findings and recommendation in this report, committed to work to
improve internal controls in order to better identify and prevent duplication with
other EPA job training programs, and provided a milestone completion date for
the recommendation.

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
THE INSPECTOR GENERAL
September 21, 2012
MEMORANDUM
SUBJECT: Environmental Job Training Program Implemented Well, But Focus Needed on
Possible Duplication With Other EPA Programs
Report No. 12-P-0843
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.
Action Required
Because you have provided a corrective action plan with a milestone date, you are not required
to provide a written response to this final report. Should you choose to provide a response, your
response will be posted on the OIG's public website, along with our memorandum commenting
on your response. Your response should be provided 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. 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 at
(202) 566-0829 or copper.carolyn@epa.gov; or Chad Kincheloe at (312) 886-6530 or
kincheloe.chad@epa.gov.
FROM: Arthur A. Elkins, Jr.
TO:
Mathy Stanislaus
Assistant Administrator for Solid Waste and Emergency Response

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Environmental Job Training Program Implemented Well,
But Focus Needed on Possible Duplication With
Other EPA Programs
12-P-0843
Table of C
Chapters
1	Introduction		1
Purpose		1
Background		1
Scope and Methodology		2
2	Selected Grants Addressed Goals, But Possibility for Duplication Exists ..	4
Selected Grants Addressed Environmental Job Training Goals		4
Possible Duplication with Other EPA Job Training Programs		4
Conclusion		5
Recommendation		6
Agency Response and OIG Evaluation		6
Status of Recommendations and Potential Monetary Benefits		7
Appendices
A Agency Response to Draft Report and OIG Comment 		8
B Distribution		10

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Chapter 1
Introduction
Purpose
We conducted this review to determine whether the U.S. Environmental
Protection Agency's (EPA's) Environmental Workforce Development and Job
Training (EWDJT, or Environmental Job Training) program is addressing its
program objectives. We also evaluated possible duplication with other EPA job
training programs. We asked the following questions:
•	How is the Environmental Job Training program implemented and is this
implementation achieving its targeted goals?
•	How is the Environmental Job Training program different from other EPA
workforce development and job training grant programs and is there any
duplication?
Background
Program Goals and Overview
The broad goals of the Environmental Job Training competitive grant program are
to:
•	Recruit and teach individuals from solid and hazardous waste-impacted
communities the skills needed to secure full-time, sustainable employment
in the environmental field
•	Focus recruitment on low-income, minority, unemployed, and under-
employed people
Job training within the program focus on assessment and cleanup of contaminated
sites, health and safety, and other environmental skills. According to EPA, these
grants help prepare people for green jobs that reduce environmental
contamination and provide more sustainable futures for the communities most
affected by solid and hazardous waste contamination.
The Environmental Job Training program was created as an expansion of and
replacement for EPA's Brownfields Job Training program. The Office of
Brownfields and Land Revitalization led the effort to create the program to more
closely collaborate on workforce development and job training with other
programs within EPA's Office of Solid Waste and Emergency Response. The
Environmental Job Training program now includes expanded training in other
environmental media outside the traditional scope of just brownfields. In fiscal
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year (FY) 2011, the first year of the program, EPA awarded 22 job-training grants
collectively valued at more than $6.5 million.
Government Focus on Duplication and Overlap
The U.S. Government Accountability Office (GAO) reports annually on selected
federal programs that have duplicative goals or activities. GAO defines
duplication as when two or more agencies or programs are engaged in the same
activities or provide the same services to the same beneficiaries. GAO states that
programs overlap when they have similar goals, devise similar strategies and
activities to achieve those goals, or target similar users. The term "potential
duplication" is used by GAO where information has not been available that would
provide conclusive evidence of duplication or overlap.
According to GAO, the Government Performance and Results Act Modernization
Act of 2010 includes a focus on identifying federal programs with duplicative
goals and activities. The Act requires each agency to identify the various federal
organizations and activities contributing to its goals. Each agency must also
describe how the agency is working with other agencies to achieve its goals.
Performance indicators to measure overall progress toward these goals as well as
the individual contribution of the underlying agencies and federal activities are
also required. These requirements provide a basis for integrating potentially
duplicative or overlapping federal activities.
EPA's 2009-2013 Grants Management Plan recognizes that effective grants
management "requires reducing or eliminating unnecessary duplication of effort."
EPA's plan includes an Agency goal to "support the Agency's vision of managing
grants to further EPA's mission of protecting human health and the environment
in accordance with the highest stewardship and fiduciary standards."
The president's 2013 proposed EPA budget states that reducing duplicative,
overlapping, or underperforming activities across government is essential to
ensure that taxpayer dollars are spent efficiently.
Scope and Methodology
We conducted this evaluation from December 2011 through August 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 evaluation objective. We believe that the evidence
obtained provides a reasonable basis for our findings and conclusions based on
our evaluation objective.
We interviewed Office of Brownfields and Land Revitalization staff and
managers responsible for implementation, design, and oversight of the
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Environmental Job Training program. Because results from the awarded FY 2011
grants were not available when we started our review, we evaluated EPA's
implementation of the grant selection and awarding process for the first year of
the program. We reviewed the implementation of the Office of Brownfields and
Land Revitalization's Environmental Job Training grant selection process to
determine whether the process established selection criteria based on and linked
to its program goals. We compared how all 22 selected FY 2011 Environmental
Job Training grants addressed EPA's selection criteria.
We identified other EPA job training programs with the potential for duplication
with the Environmental Job Training program by searching official government
records and databases. Our search criteria were key words for the populations,
communities, and training targeted by the Environmental Job Training program.
Our search identified over 30 EPA programs meeting one or more of the criteria.
For programs meeting more than one criterion, we reviewed the program
description and other information available and, where applicable, contacted the
EPA program offices to verify the potential for duplication with the
Environmental Job Training program.
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Chapter 2
Selected Grants Addressed Goals,
But Possibility for Duplication Exists
EPA effectively established and adhered to competitive criteria that resulted in
selection of job training proposals that addressed the broad goals of the
Environmental Job Training program. However, internal controls to identify and
prevent duplication with other EPA job training programs were not in place. We
identified other EPA programs with potential to duplicate Environmental Job
Training program activities. Consequently, there is some risk of duplication in
EPA awards for job training programs.
Selected Grants Addressed Environmental Job Training Goals
FY 2011 grant recipients were selected by the Assistant Administrator for Solid
Waste and Emergency Response based on highest rank and other applicable
factors. Selected grantees first passed the threshold eligibility criteria,1 and were
then scored according to the ranking criteria.2 We found evidence that all
22 selected grantees addressed program goals in their applications.
Possible Duplication With Other EPA Job Training Programs
The Environmental Job Training program did not have internal controls to
identify and prevent duplication with other EPA-funded environmental job
training programs.
Other EPA Programs With Potential for Duplicating Environmental
Job Training Activities
We identified other EPA programs that could possibly duplicate Environmental
Job Training activities. Potentially duplicative activities included:
•	Providing job skills training to secure full-time employment in the
environmental field
•	Job search or placement activities
•	Targeting similar populations (e.g., minorities, low income, unemployed,
and under-employed)
•	Serving communities affected by hazardous waste sites
1	Threshold eligibility criteria included applicant eligibility, required training, and funding amount.
2	Ranking criteria included community need, training program description and anticipated outcomes and outputs,
programmatic capability, institutional capacity, community and employer partnerships, and budget/resources.
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For example, the Super fund Job Training Initiative (SuperJTI) contract program
is a job readiness program that provides training and employment opportunities
for citizens living in communities affected by hazardous waste sites. Many of
these areas are environmental justice communities and minority and low-income
neighborhoods. SuperJTI trainees acquire skills to work on environmental
remediation projects, Superfund site cleanup projects, and construction projects.
The Surveys, Studies, Investigations, Training and Special Purpose Activities
Relating to Environmental Justice grant program and the Environmental Justice
Small Grant Program included activities similar to the Environmental Job
Training Program. Similar activities included recruiting, training, and securing
full-time employment. Projects selected for these other programs could also be
from communities impacted by solid and hazardous waste.
Lack of Internal Controls Risks Duplication
The Environmental Job Training program does not have internal controls in place
to identify and prevent duplication of EPA efforts and spending. Such internal
controls could include formal policies, written procedures, or required checklists
to prevent duplication of EPA efforts and spending. Consequently, there is some
risk of duplication in EPA awards for job training programs by not having internal
controls to prevent duplication.
Job Training Activities Must Complement But Not Duplicate
EPA recognizes the need to identify possible duplication. In FY 2012, EPA added
a requirement to its Environmental Job Training grant application for applicants
to demonstrate that their proposed project will complement, but not duplicate,
other federally funded environmental job training programs. However, assigning a
determination of duplication to an applicant may not be an effective internal
control unless EPA has assurance that applicants possess the necessary knowledge
and skills to perform this activity.
Conclusion
EPA effectively established the Environmental Job Training grant application
criteria for FY 2011. This resulted in selection of grantees that addressed EPA
program goals. However, the Environmental Job Training program does not have
internal controls to identify and prevent duplication with other EPA-funded
programs. The Environmental Job Training program needs to create internal
controls to reduce or eliminate the risk of duplication in awarding EPA funds
through the Environmental Job Training program and other EPA programs.
Effective internal controls should identify all EPA job training programs with
similar goals and include measurable individual program contributions or
outcomes to meet these goals. This would provide a basis for integrating
potentially duplicative, overlapping, or complementary job training programs.
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Recommendation
We recommend the Assistant Administrator for Solid Waste and Emergency
Response:
1. Establish internal controls for coordination with other EPA-funded job
training programs to prevent duplication of effort and spending.
Agency Response and OIG Evaluation
The Office of Solid Waste and Emergency Response (OSWER) agreed with the
findings and recommendation in this report, and committed to work to improve
internal controls in order to better identify and prevent duplication with other EPA
job training programs. We reviewed OSWER's comments and made changes to the
report as appropriate. Appendix A provides the full text of OSWER's response and
the OIG's comments.
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Status of Recommendations and
Potential Monetary Benefits
RECOMMENDATIONS
POTENTIAL MONETARY
BENEFITS (In $000s)
Rec.
No.
Page
No.
Subject
Status1
Action Official
Planned
Completion
Date
Establish internal controls for coordination with
other EPA-funded job training programs to prevent
duplication of effort and spending.
Assistant Administrator
for Solid Waste and
Emergency Response
9/30/13
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 Response to Draft Report
and OIG Comment
MEMORANDUM
SUBJECT: Response to Draft Audit Report, "Environmental Job Training Program
Implemented Well, But Focus Needed on Possible Duplication
With Other EPA Programs" Project No. OPE-FY12-2506
FROM: Mathy Stanislaus
Assistant Administrator
TO:	Carolyn Copper
Assistant Inspector General for Program Evaluation
Thank you for the opportunity to comment on the issues and recommendations in the subject
audit draft report. We agree with the findings and recommendation in this report, and we will
work to improve internal controls in order to better identify and prevent duplication with other
EPA job training programs. Our comments on the report and recommendation are below.
Comment on the Report
Please note on page 4 of the draft report that "job readiness training" is not an eligible use of
grant funds under the Environmental Workforce Development and Job Training (EWDJT)
Program, as stated on page 7 of the EWDJT Application Guidelines.
http://www.epa.gov/oswer/docs/grants/epa-oswer-oblr-l 1-01 .pdf
OIG Response: OSWER's cited source, "EWDJT Application Guidelines," for "job readiness
training," is specific to the ineligibility of grant funds for the purpose of "job readiness training"
for developing resumes and acquiring interview skills. The OIG report's context is specific to the
SuperJTI contract program described as a job readiness program that provides training to work
on environmental remediation and clean-up projects. To avoid any misunderstanding or
confusion, the OIG has removed the word "readiness" from the first bullet under the report
section titled "Other EPA Programs With Potential for Duplicating Environmental Job Training
Activities." We retained "readiness" in the specific context of the SuperJTI program.
Specific Recommendation and Response
Recommendation: Establish internal controls for coordination with other EPA-funded job
training programs to prevent duplication of effort and spending.
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Response: We will add language under the current "demonstration of non-duplication" threshold
criterion in the EWDJT Application Guidelines that states "applicants must demonstrate the
proposed training project does not duplicate other federally-funded programs for environmental
job training in the target community. This will include the programs currently listed, as well as
the Superfund Job Training Initiative; the Environmental Justice Small Grants Program CFDA
66.604; and the Surveys, Studies, Investigations, Training, and Special Purpose Activities
Relating to Environmental Justice grants program CFDA 66.309." In addition, OSWER's Office
of Brownfields and Land Revitalization and Office of Superfund Remediation and Technology
Innovation will work with the Office of Environmental Justice (OEJ) to conduct an internal
review of proposals submitted in response to future competitions to help avoid potential
duplication. This potential duplication screening has already been initiated as part of a threshold
review with the National Institute of Environmental Health Sciences (NIEHS) and the
Department of Labor (DOL). These changes will be implemented for the FY13 EWDJT grant
competition. The release date of the FY13 RFP has not yet been determined.
OIG Response: The OIG recognizes OSWER's commitment to work with the Office of
Environmental Justice to conduct an internal review of other EPA-funded job training programs
as addressing the intent of the OIG recommendation. The OIG accepts the completion date for
the above corrective action plan to be no later than the end of FY 2013 (September 30, 2013).
OSWER's response indicates that it intends to continue the practice of assigning a determination
of duplication to the applicant. OSWER stated that language will be added under the current
"demonstration of non-duplication" threshold criterion in the EWDJT Application Guidelines
that states applicants must demonstrate the proposed training project does not duplicate other
federally-funded programs for environmental job training in the target community.
The OIG continues to maintain, as stated in this report, that assigning a determination of
duplication to an applicant may be an ineffective internal control unless EPA has assurance that
applicants possess the necessary knowledge and skills to perform the duplication determination.
If you have any questions regarding this response, please contact David Lloyd at 202-566-2731
Llovd.DavidR@epa.gov or Gail Cooper at 202-566-0168 Cooper.GailAnn@epa.gov.
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Appendix B
Distribution
Office of the Administrator
Assistant Administrator for Solid Waste and Emergency Response
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
Audit Follow-Up Coordinator, Office of Solid Waste and Emergency Response
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