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U.S. Environmental Protection Agency
Office of Inspector General
At a Glance
20-N-0218
July 6, 2020
What Are Management
Challenges?
According to the GPRA
Modernization Act of 2010
(GPRA stands for Government
Performance and Results Act),
major management challenges
are programs or management
functions within or across
agencies that have greater
vulnerability to waste, fraud,
abuse, and mismanagement,
and where a failure to perform
well could seriously affect the
ability of an agency or the
federal government to achieve
its mission or goals.
Per the Reports Consolidation
Act of 2000, each fiscal year the
Office of Inspector General is to
identify major management
challenges for the U.S. Chemical
Safety and Hazard Investigation
Board. In FY 2020, we examined
whether the two management
challenges we identified in
FY 2019—as detailed in Report
No. 19-N-0156, issued May 20,
2019—were addressed. We
also sought to identify any new
challenges.
This report addresses the
three CSB goals:
•	Prevent recurrence of
significant chemical incidents.
•	Advocate safety and achieve
change.
•	Create and maintain an
engaged, high-performing
workforce.
Address inquiries to our public
affairs office at (202) 566-2391 or
OIG WEBPOSTINGS@epa.gov.
List of OIG reports.
Fiscal Year 2020 U.S. Chemical Safety and Hazard
Investigation Board Management Challenges
Based on our continuous audit, evaluation, and
investigative work, we have determined that the
two management challenges we identified in
FY 2019 have not been addressed. We also
identified a new challenge for FY 2020 related to
the coronavirus pandemic—that is, the SARS-CoV-2 virus and resultant
COVID-19 disease. This new challenge affects all government agencies.
Management Challenge (Continuing): Accomplishment of CSB Mission Is
Impaired Until New Board Members Are Selected
The Clean Air Act Amendments of 1990 authorized the creation of the CSB and
established a board of five members, including a chairperson, that is responsible
for major budgeting decisions, strategic planning and direction, general Agency
oversight, and approval of investigation reports and studies. In March 2020, the
U.S. Senate confirmed a new CSB chairperson. Due to term expirations and
resignations of the other board members, the chairperson was, as of June 2020,
the only remaining board member.
Having only one member impairs the function of the CSB, as all functions rest
with that one member. CSB Order 028, Executive and Administrative Functions
of the Board, delineates executive and administrative functions of the board,
including specific authorities of the chairperson and duties of the board as a
whole. The Order does not explicitly address a situation when the only member
of the board is the chairperson. Regardless, workload limitations arising from
one board member attempting to perform the work of five affect the
accomplishment of the board's technical responsibilities, including accident
reconstruction, safety engineering, human factor identification, toxicology
reviews, and air pollution regulation assessments.
Management Challenge (Continuing): CSB Has Not Developed Policy on
Board Member Responsibilities
In FY 2018, we reported multiple instances when a board member acted
inconsistently with established practices or inappropriately provided information
to outside entities. The CSB previously agreed to develop new policy, but per the
Agency's general counsel, the board decided that a Senate-confirmed
chairperson should approve any changes to policy affecting the board.
Management Challenge (New): CSB Must Continue Operations During the
Coronavirus Pandemic
The CSB must rely on its internal controls to continue operations to the extent
practicable and to safely return employees to work at CSB facilities.
Unaddressed management
challenges will impede the
ability of the CSB to function
effectively.

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