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U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF INSPECTOR GENERAL
U.S. Chemical Safety Board
CSB Purchase Card
Program at Low Risk for
Unauthorized Purchases
Report No. 18-P-0218
July 3, 2018
LOW RISK
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U. S. Government Ta* Exempt
Fiscal Year 2017
588 transactions:
$306,537
convenience checks:
$14,704

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Report Contributors:
Michael D. Davis
Randy Holthaus
Philip J. Cleveland
Abbreviations
CSB U.S. Chemical Safety and Hazard Investigation Board
FY	Fiscal Year
OIG Office of Inspector General
OMB Office of Management and Budget
U.S.C. United States Code
Cover Image: Shows total transactions for both purchase cards and convenience checks, as well
as the OIG's determination of risk. (OIG image)
Are you aware of fraud, waste or abuse in an
EPA or CSB program?
EPA Inspector General Hotline
1200 Pennsylvania Avenue, NW (2431T)
Washington, DC 20460
(888) 546-8740
(202) 566-2599 (fax)
OIG Hotline@epa.qov
Learn more about our OIG Hotline.
EPA Office of Inspector General
1200 Pennsylvania Avenue, NW (2410T)
Washington, DC 20460
(202) 566-2391
www.epa.gov/oiq
Subscribe to our Email Updates
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At a Glance
Why We Did This Project
The Office of Inspector General
(OIG) performed this risk
assessment of the U.S.
Chemical Safety and Hazard
Investigation Board's (CSB's)
purchase card use during fiscal
year (FY) 2017, as required by
the Government Charge Card
Abuse Prevention Act of 2012.
The act requires the Inspector
General of each agency to
conduct periodic assessments
of the agency's purchase card
or convenience check program
to analyze the risks of illegal,
improper or erroneous
purchases.
In FY 2017, we conducted a
risk assessment of the CSB's
purchase card program (EPA
OIG Report No. 17-P-0303.
July 5, 2017). Our FY 2017 risk
assessment found that the CSB
made improvements to its
internal controls, and we
determined that the program
was at low risk for illegal,
improper or erroneous
purchases and payments. As a
result, we conducted another
risk assessment—not an
audit—in FY 2018.
This report addresses the
following CSB goal:
• Create and maintain an
engaged, high-performing
workforce.
Send all inquiries to our public
affairs office at (202) 566-2391
or visit www.epa.gov/oiq.
CSB Purchase Card Program at Low Risk for
Unauthorized Purchases
What We Found
The CSB purchase card program is at low risk for
unauthorized purchases. We found, with one
exception, that the CSB complied with applicable
plans and guidance. The CSB should continue to
follow the requirements set forth in its Charge Card
Management Plan and in Office of Management and
Budget guidance governing agency purchase cards.
The CSB's purchase
card program, through
which the agency spent
$321,241 in FY 2017, is
at low risk for
unauthorized purchases.
We reviewed a sample of 18 purchase card and two convenience check
transactions and found that 17 of the purchase card and both of the convenience
check transactions were legitimate. In one instance, CSB personnel identified a
transaction made by an outside party as fraudulent, took proper steps to reverse
the charge, and closed the associated charge card.
As part of our current risk assessment, we followed up on an issue that we
identified in our FY 2017 risk assessment: split transactions. We reviewed
FY 2017 transactions to determine whether any were split transactions, and we
found none. We also confirmed that the CSB addressed the one
recommendation we made in our FY 2017 report.
Based on our risk assessment, we make no recommendations in this report.
Listing of OIG reports

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
THE INSPECTOR GENERAL
July 3, 2018
Dr. Kristen Kulinowski, Ph.D.
Interim Executive Authority and Member
U.S. Chemical Safety and Hazard Investigation Board
1750 Pennsylvania Avenue NW, Suite 910
Washington, D.C. 20006
Dear Dr. Kulinowski:
This is our report on our risk assessment of the U.S. Chemical Safety and Hazard Investigation Board's
(CSB's) purchase card use during fiscal year 2017. This report represents the opinion of the Office of
Inspector General (OIG) and does not necessarily represent the final CSB position.
You are not required to respond to this report because this report contains no recommendations.
However, if you submit a response, it will be posted on the OIG's 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 along with corresponding
justification.
We will post this report to our website at www.epa.gov/oig.
Jsi nrprpl v
Arthur A. Elkins Jr.

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CSB Purchase Card Program at Low Risk	18-P-0218
for Unauthorized Purchases
	 Table of C	
Purpose	 1
Background	 1
Scope and Methodology	 1
Prior Report	 2
Results	 2
CSB Is Compliant with OMB Split-Purchase Transaction Requirements	 3
Conclusion	 3
CSB Response	 3
Appendix
A Distribution	 4

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Purpose
Our objective was to perform a risk assessment of the U.S. Chemical Safety and
Hazard Investigation Board's (CSB's) purchase card use during fiscal year
(FY) 2017. The Government Charge Card Abuse Prevention Act of 2012, at
41 U.S.C. § 1909(d), requires the Inspector General of each agency to conduct
periodic assessments of the agency's purchase card or convenience check
program to analyze the risks of illegal, improper or erroneous purchases.
Background
The CSB is an independent federal agency charged with investigating industrial
chemical incidents and hazards. Headquartered in Washington, D.C., the agency's
board members are appointed by the President and confirmed by the U.S. Senate.
The CSB was established by the Clean Air Act Amendments of 1990 and became
operational in 1998.
The Government Charge Card Abuse Prevention Act of 2012 reinforced
administration efforts to prevent waste, fraud and abuse of governmentwide
charge card programs. The act requires all executive branch agencies to establish
and maintain safeguards and internal controls for purchase cards, travel cards,
integrated cards and centrally billed accounts. The act also requires the Office of
Inspector General (OIG) to conduct periodic risk assessments of an agency's
purchase card or convenience check program to analyze the risks of illegal,
improper or erroneous purchases. These risk assessments will be used to
determine the necessary scope, frequency and number of audits that the OIG
needs to conduct of these programs.
Scope and Methodology
We conducted this purchase card program risk assessment from March 2018 to
June 2018 in accordance with generally accepted government auditing standards
issued by the Comptroller General of the United States. Those standards require
that we plan and perform our project to obtain sufficient, appropriate evidence to
provide a reasonable basis for our findings and conclusions based on our
objective. We believe that the evidence obtained provides a reasonable basis for
our findings and conclusions based on our objective.
We reviewed, analyzed and documented the CSB's internal controls. In FY 2017,
the CSB completed 588 purchase card transactions with a total net value of
$306,537, and seven convenience check transactions with a total net value of
$14,704, for a grand total value of $321,241. We judgmentally selected a sample
of 18 purchase card transactions, valued at $35,439, and two convenience check
transactions, valued at $5,468. We selected the transactions based on their
amounts and types, and we reviewed each one for legitimate purchases, proper
authorization and approvals based on the CSB's Charge Card Management Plan
18-P-0218
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requirements. In addition, we analyzed the CSB's management plan to determine
whether it had controls to prevent fraud, waste and abuse of purchase cards.
Prior Report
In FY 2017, the OIG conducted a risk assessment of the CSB's purchase card
program. We issued Report No. 17-P-0303. CSB Purchase Card Program at Low
Risk for Unauthorized Purchases, on July 5, 2017, and assessed the CSB's
purchase card program as low risk. We made one recommendation in the report.
The CSB completed its planned corrective action in March 2018. Based on the
results of that risk assessment, the OIG determined that another risk assessment—
not an audit—should be performed in FY 2018.
Results
The CSB purchase card program continues to be at low risk for unauthorized
purchases. We found—with one exception, when a convenience check was used
for a purchase over $2,500—that the CSB complied with applicable plans and
guidance. The CSB should continue to follow the requirements set forth in its
Charge Card Management Plan and in the Office of Management and Budget's
(OMB's) guidance1 governing agency purchase cards.
Our review of the 18 sampled purchase card transactions and two sampled
convenience check transactions found that 17 of the purchase card and both of the
convenience check transactions were legitimate. In the one purchase card
transaction that was not found to be legitimate, the CSB had identified the
transaction as fraudulently made by an outside party, took proper steps to reverse
the charge, and closed the associated charge card.
We identified two transactions that required us to follow up with the CSB:
•	One purchase card transaction exceeded the $3,500 purchase card limit.
•	One convenience check transaction exceeded the CSB-imposed limit of
$2,500.
The purchase card transaction was made to a foreign vendor after the CSB
determined that a purchase card was the best method of payment. The CSB
provided support showing that the transaction was properly executed and adhered
to federal regulations. For the convenience check transaction, a CSB reviewing
official had identified the error and instructed the employee who made the error
regarding CSB policy. These actions were adequate and showed that the CSB has
proper internal controls in place for such transactions.
1 The OMB's two guidance documents related to purchase cards are Implementation of the Government Charge
Card Abuse Prevention Act of 2012, Memorandum M-13 -21, September 6, 2013; and Improving the Management of
Government Charge Card Programs, Appendix B to OMB Circular No. A-123, January 15, 2009.
18-P-0218
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CSB Is Compliant with OMB Split-Purchase Transaction Requirements
The CSB is compliant with the OMB's split-purchase transaction requirements. In
our FY 2017 risk assessment, we identified unallowable split transactions as a
possible issue for the CSB purchase card program. As a result, during our current
review of the CSB FY 2017 Account Activity Report, we looked for identical
transactions, which possibly signify that purchases are being split to avoid
complying with acquisition thresholds. Our review identified two instances where
there were two separate transactions made on the same day to the same vendor for
the same amount. These transactions appeared to be split transactions.
The first instance of duplicate transactions occurred on February 14, 2017, for
$2,500 each ($5,000 total). The second instance of duplicate transactions occurred
on September 26, 2017, for $3,200 each ($6,400 total). We analyzed these
transactions further; if each of the duplicate charges was intended to be grouped
with the initial charge for one purchase, then the overall transactions would have
exceeded the $3,500 micro-purchase threshold. Our analysis of these two charges,
however, found that corresponding credits were posted for $2,500 and $3,200,
respectively, on the same day, thereby offsetting the second transactions. These
credits resulted in only one charge to the merchant in each case.
Conclusion
Based on the results of our risk assessment, we determined that the CSB's
purchase card program is at low risk. Therefore, in FY 2019, we plan to conduct
another annual risk assessment, in accordance with OMB Memorandum M-13-21,
for the CSB's FY 2018 purchase card program transactions. Based on the results
of our risk assessment, we make no recommendations.
CSB Response
The CSB agreed with our report and did not provide written comments.
18-P-0218
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Appendix A
Distribution
Interim Executive Authority and Member, U.S. Chemical Safety and Hazard Investigation Board
Board Members, U.S. Chemical Safety and Hazard Investigation Board
General Counsel, U.S. Chemical Safety and Hazard Investigation Board
Director of Administration and Audit Liaison, U.S. Chemical Safety and Hazard
Investigation Board
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