OFFICE OF INSPECTOR GENERAL
U.S. ENVIRONMENTAL PROTECTION AGENCY
November 30, 2020 | Report No. 21-E-0030
EPA's Initial Plans for Returning to the Office
Incorporate CDC Guidance but Differ by Location
EPA OIG's Response to the
COVID-19 Pandemic
Source: Centers for Disease Control and
Prevention image.
Evaluation Purpose:
Determine the EPA's national
strategy for implementing federal
guidelines to protect the health and
safety of its workforce when
reopening its locations that were
closed due to the coronavirus
pandemic.
This report addresses the
following:
•	Operating efficiently and
effectively.
This evaluation addresses a top
EPA management challenge:
•	Maintaining operations during
pandemic responses.
Address inquiries to our public affairs
office at (202) 566-2391 or
OIG WEBCOMMENTS@eDa.gov.
Full list of EPA OIG reports.
Why We Did This Evaluation
The Office of Inspector General for the U.S. Environmental Protection
Agency initiated work in July 2020 under Project No. QA&E-FY20-0241
to determine the EPA's national strategy for implementing federal
guidelines to protect the health and safety of its workforce when
reopening its locations that were closed due to the coronavirus
pandemic.
While conducting our evaluation, we identified disparity among the
13 reopening plans we reviewed for Phases 1 and 2. We are therefore
issuing this report to inform the EPA of this matter before locations
begin to enter Phase 3. We plan to review implementation of the
reopening plans as Agency locations advance to Phase 3 and more
staff return to their offices.
Background
In response to the coronavirus pandemic—that is, the SARS-CoV-2
virus and resultant COVID-19 disease—the EPA closed most Agency
facilities to all but mission-critical personnel. The EPA continued its
operations remotely, with most of its workforce teleworking. The
Agency estimated that 97 percent of its workforce was teleworking in
August 2020.
Federal and EPA Guidelines on Reopening Operations
In March 2020, the Occupational Safety and Health Administration
developed "COVID-19 planning guidance based on traditional infection
prevention and industrial hygiene practices. It focuses on the need for
employers to implement engineering, administrative, and work
practice controls and personal protective equipment (PPE), as well as
considerations for doing so."
In April 2020, the White House released nationwide guidelines for
Guidelines: Opening Up America Again, which comprise "a three-
phased approach based on the advice of public health experts ... to
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Reopening the EPA workplace
criteria:
V Occupational Safety and Health
Administration: Guidance on
Preparing Workplaces for COVID-19
I Office of Management and Budget;
Office of Personnel Management:
Memorandum M-20-23, Aligning
Federal Agency Operations with the
National Guidelines for Opening Up
America Again
I CDC: Interim Guidance for
Businesses and Employers
Responding to Coronavirus
Disease 2019 (COVID-19)
I EPA: Memorandum, EPA's Office
Operations During the COVID-19
Pandemic
9 EPA: Guidance on Returning to the
Workplace
Source: OIG analysis of federal guidance.
(EPA OIG image)
help state and local officials when reopening their economies, getting
people back to work, and continuing to protect American lives."
On April 20, 2020, the Office of Management and Budget and the
U.S. Office of Personnel Management jointly issued
Memorandum M-20-23. Aligning Federal Agency Operations with the
National Guidelines for Opening Up America Again. This memorandum
provides the framework for agencies to begin a controllable, steady
return to normal operations that is in compliance with the three
phases outlined in the White House's Guidelines: Opening Up America
Again. This memorandum was supplemented on May 6, 2020, by the
Centers for Disease Control and Prevention's Interim Guidance for
Businesses and Employers Responding to Coronavirus Disease 2019
(COVID-19), which provides general safety and health measures that
businesses and employers can implement when reopening operations.
In May 2020, the EPA administrator issued a memorandum to all staff
informing them of the Agency's reopening plans and phased approach
to reopening EPA locations. The EPA also developed guidance for a
phased reopening of the Agency's facilities, which outlined how to
safely reoccupy offices to meet the reopening criteria defined in
federal guidance. Figure 1 summarizes federal and EPA reopening
guidance.
Figure 1: Federal and EPA guidance on reopening the workplace
Issued bv
Guidance on Preparing Workplaces for
Occupational Safety and
Health Administration
Date
March 2020
Contains recommendations
and information to help employers "identify
risk levels in workplace settings & to
determine any appropriate control
measures to implement."
Issued bv
The White House
Date
April 2020
Guidelines: Opening Up America Again:
Contains a health-based vision for putting
the nation back to work and presents
guidelines on a three-phased approach,
based on the advice of public health
experts.
Issued bv
Office of Management
and Budget;
Office of Personnel
Management
Date
April 20, 2020
Memorandum M-20-23, Aligning Federal
Agency Operations with the National
Guidelines for Opening Up America
Outlines data-driven approach for
agencies to evaluate site-specific
conditions and comply with state and local
health department requirements and the
White House's Guidelines: Opening Up
America Again.
Issued bv
Interim Guidance for Businesses and
Employers Responding to Coronavirus
CDC
Date
May 6, 2020
Emphasizes
the White House's Guidelines: Opening Up
America Again, as well as a phased
approach based on state or local levels of
transmission and healthcare capacity.
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Protocols for EPA's phased
reopening:

Phase 0


Facility closed for at least seven days
for cleaning


CLOSED


Phase 1
•	Optional return to workplace
•	Encouraged telework
•	Expanded work hours
•	Self-screening
•	Social distancing in common areas
•	Essential travel only
•	Special accommodations for
vulnerable individuals
•	No visitors


Phase 2


•	Encouraged telework if feasible
•	Normal work hours
•	Special accommodations for
vulnerable individuals
•	Self-screening
•	Social distancing in common areas
•	Mission-essential visitors allowed
•	Unrestricted travel (requires
management review)


Phase 3


•	Resume normal workplace status
•	Maintain health and safety protocols

Source: OIG analysis of EPA data.
(EPA OIG Image)
Issued bv
EPA Administrator
Date
May 21, 2020
Memorandum, EPA's Office Operations
During the COVID-19 Pandemic:
Provides a plan for an eventual phased
return to EPA offices using a data-driven
approach for a "rolling reopening" to
ensure staff health and safety.
Issued bv
EPA, Office of Mission
Support Principal Deputy
Assistant Administrator
Date
May 27, 2020
Guidance on Returning to the
Outlines how to safely
reoccupy offices that meet the criteria
defined in the White House's Guidelines:
Opening Up America Again, identifies new
resources that reflect the Agency's
adoption of the CDC's Interim Guidance,
and recommends strategies for offices that
are resuming normal or phased business
operations.
Source: OIG analysis of reopening guidance. (EPA OIG figure)
EPA's Phased Reopening Strategy
When making decisions about whether to reopen specific Agency
locations, the EPA reviews the White House's Guidelines: Opening Up
America Again, which references adherence to CDC guidelines, and
Memorandum M-20-23. These guidelines incorporate "gating" criteria,
which are conditions that, per the White House's guidelines, "must be
met in a state or county (in addition to core preparedness
responsibilities)" before an entity can proceed to the next phase in the
overall three-phased reopening process (Table 1).
Table 1: Gating criteria
Symptoms
Cases
Hospitals
Downward trajectory of
influenza-like
illnesses reported within
a 14-day period.
AND
Downward trajectory of
COVID-like syndromic
cases reported within a
14-day period.
Downward trajectory of
documented cases
within a 14-day period.
OR
Downward trajectory of
positive tests as a
percent of total tests
within a 14-day period
(flat or increasing
volume of tests).
Treatment of all patients
without crisis care.
AND
Robust testing program
in place for at-risk
healthcare workers,
including emerging
antibody testing.
Source: EPA OIG representation of the White House's Guidelines: Opening Up
America Again. (EPA OIG table)
In line with the White House's guidance, the Agency's strategy
provides for a phased reopening of its locations. All EPA locations with
plans to reopen—including laboratories and satellite offices—must
begin in Phase 0, an EPA-specific phase that requires locations to be
unoccupied for seven days for cleaning before proceeding to Phase 1.
The EPA's reopening process ends with Phase 3, when locations may
resume their normal workplace status with workplace flexibilities and
social distancing plans in place.
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.JL
¦ 111111 ¦ 11 ¦
Congressional interest in federal
reopening during 2020:
•	June 15: Subcommittee on
Government Operations requests
the OIG to review the EPA's
reopening plans and procedures.
•	July 10: The OIG replies to the
Subcommittee, agreeing to review
"certain aspects" of its request
within the scope of an already
OIG-initiated evaluation.
•	July 14: The Homeland Security
and Governmental Affairs
Committee requests information
from several agencies, including
the EPA, about their reopening
plans.
•	July 27: The OIG requests a copy
of the EPA's response to the
July 14 request for information.
•	As of August 31: The EPA has not
responded to the July 14 request
for information.
To implement the Agency's overarching reopening strategy, the EPA's
locations across the country developed their own specific reopening
plans. To aid Agency facility managers in evaluating their preparedness
to reopen locations and protect the health and safety of the EPA
workforce, the Agency developed nationwide guidance for Agency
facility managers to follow when evaluating their preparedness to
reopen locations and to protect the health and safety of the EPA
workforce. This guidance is posted on the Agency's COVID-19
intranet site:
•	Facility Management Checklist, May 2020. Addresses building
operations, services, and amenities, among other areas. The
checklist recommends protocols for facility preparation and
entry screening to facilitate the safe return of nonessential
employees to their physical EPA duty stations.
•	EPA Return to the Workplace: Employee Information,
May 2020. Summarizes the Agency's plan and process to
reopen its facilities. This information sheet states, "Each facility
should follow the EPA Facility Checklist."
•	EPA COVID-19 Guidance for Contact Tracing and Employee
Notification Guidance for EPA Managers and Supervisors,
May 2020. Provides information and email templates for
communication about and reporting COVID-19 cases affecting
the Agency.
•	EPA Self Assessment to Stop the Spread of COVID-19, updated
July 2020. Asks a series of health-related questions to help
employees determine whether they should stay home or
return to the office.
Congressional Interest in EPA's Reopening Plans
On June 15, 2020, the Subcommittee on Government Operations
requested that the "Office of Inspector General examine the plans and
procedures of the U.S. Environmental Protection Agency for returning
employees to federal offices in the wake of the coronavirus
pandemic." On July 10, 2020, the OIG informed the Subcommittee
that "aspects of your request will be considered within the scope of a
self-initiated OIG evaluation of the EPA's response to the White
House's Guidelines for Opening Up America Again."
On July 14, 2020, Senator Gary Peters, ranking member of the
Homeland Security and Governmental Affairs Committee, sent letters
to several agencies, including the EPA, seeking details on their plans to
safely reopen offices. On July 27, 2020, we requested the EPA to
provide us with a copy of its response to Senator Peters. As of
October 7, 2020, the Agency had not responded to Senator Peters,
and we have therefore not received a copy of the Agency's response.
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reopening plans refer
to the EPA's required
Facility Management
Checklist.
Source: OIG analysis of EPA data.
(EPA OIG image)
Scope and Methodolo
We conducted this evaluation from July 2020 to September 2020. This
evaluation was conducted using Quality Standards for Inspection and
Evaluation, issued by the Council of the Inspectors General on
Integrity and Efficiency. These standards require that we plan and
perform the evaluation to obtain sufficient, appropriate evidence to
provide a reasonable basis for our findings, conclusions, and
recommendations based on our evaluation objective. We adhered to
the OIG's quality control procedures for ensuring that the information
in this report is accurate and supported. More information on our
scope and methodology is in Appendix B.
Responsible Office
According to its website, the EPA's Office of Mission Support, or OMS,
"leads the agency's core mission support functions including
protection of EPA's facilities and other critical assets nationwide."
As such, the OMS is responsible for administration and resources.
What We Found
All 13 locations we reviewed developed reopening plans to protect the
health and safety of their returning workforces. These reopening plans
incorporate the elements outlined in the CDC's Interim Guidance, but
how they implement the following health and safety measures
outlined in the CDC's Interim Guidance differs substantially in many
respects:
•	Face coverings.
•	Social distancing.
•	Ventilation systems.
•	Cleaning and disinfecting.
•	Interaction with visitors and non-EPA employees.
•	Public transportation.
Four (31 percent) of the 13 reopening plans we reviewed refer to the
EPA's Facility Management Checklist, which references certain aspects
of the CDC guidelines. OMS staff told us that EPA locations were
provided flexibility to develop their plans based on varying state and
local conditions. Also, in response to our findings, Agency management
said that facility managers were not required to follow or refer to the
Facility Management Checklist in the location-specific written plans.
The checklist, however, says that it "should be used by EPA facilities,
offices, laboratories, or sites prior to allowing non-essential employees
to return to their EPA physical duty station," although it acknowledges
that not all checklist items are applicable to all EPA locations.
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How to wear a mask correctly.
Source: CDC.gov. (CDC image)

11 of 13
reopening plans
require face coverings
to be worn in
common areas
Source: OIG analysis of EPA data.
(EPA OIG image)
lof 13
reopening plans
addresses the
enforcement of
face covering
requirement
Source: OIG analysis of EPA data.
(EPA OIG image)
How to social distance.
Source: CDC.gov. (CDC image)
Face Coverings
The CDC's Interim Guidance states that the "CDC recommends wearing
a cloth face covering as a measure to contain the wearer's respiratory
droplets and help protect their co-workers and members of the
general public."
Eleven of the 13 reopening plans we evaluated require face coverings
to be worn in common areas, while two only recommend it. Both the
OMS principal deputy assistant administrator and the OMS chief of
staff provided us with the same rationale for these differences on two
separate occasions: the EPA is following state and local requirements
with respect to face coverings, and it is expected that there would be
differences.
Ten of the reopening plans that require face coverings do not discuss
how this requirement will be enforced. The Research Triangle Park,
North Carolina, reopening plan is the only one that specifically
addresses how the location will enforce its face covering mandate:
Face coverings are required on campus in all public areas in the building.
Individuals observed out of compliance will be asked to use a face
covering and reported to their supervisor or COR [contracting officer's
representative], A second offense may result in the individual being
removed from campus.
In response to our findings, the Agency indicated that enforcement is
addressed in EPA Return to the Workplace Supervisory FAQs, which
outlines possible EPA enforcement action when employees refuse to
wear a cloth face covering in the EPA workspace where a cloth face
covering is required.
Social Distancing
The CDC defines social distancing as "staying at least six feet from
other people who are not from your household." The CDC's Interim
Guidance states that employers should "establish policies and
practices for social distancing" and outlines possible strategies to help
employees maintain social distancing. These strategies include closing
or limiting access to common areas and implementing flexible work
schedules—such as staggered shifts—to limit the number of
employees in the workplace at the same time.
The majority of the 13 reopening plans we reviewed are specific as to
how many people can be in an elevator (ten plans) or restroom
(nine plans) in the buildings in their specific locations, while the others
generally recommend that people "limit occupancy," provide varying
guidance, or do not address occupancy limits at all.
Flexible work schedules were implemented agencywide on March 17,
2020, via a mass mailer from the EPA administrator. Yet, only four of
the 13 locations we evaluated either employ or plan to employ
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reopening plans
address adequate
building ventilation
Source: OIG analysis of EPA data.
(EPA OIG image)
staggered work shifts to help with social distancing. The other
locations have either not comprehensively adopted this approach or
remained silent regarding this approach.
Ventilation Systems
The CDC's Interim Guidance says that employers should "[cjonsider
improving the engineering controls using the building ventilation
system/' such as increasing the ventilation rates, ensuring that
ventilation systems operate properly and provide acceptable indoor air
quality, and increasing outdoor air ventilation.
Two of the 13 reopening plans we reviewed require facility managers
to confer with the U.S. General Services Administration to ensure that
building ventilation is adequate: Regions 5 and 6. Five apply the CDC's
Interim Guidance: Regions 1, 2, 4, and 7, and Cincinnati. Three apply
unique guidelines that they developed: Regions 3, 9, and 10. And three
do not address ventilation: Region 8, headquarters, and Research
Triangle Park. In addition, only Regions 9 and 10 address the
maximization of outside air. For example, the Region 10 reopening
plan states:
The air intake currently uses MERV13 filters in all office buildings, which
will be replaced by MERV 14 filters prior to staff returning. According to
the American Society of Heating, Refrigeration, and Air-Conditioning
Engineers (ASHRAE) "MERV 13 filters are efficient at capturing airborne
viruses, but MERV 14 rated filters are preferred."
The OMS principal deputy assistant administrator told us that
even though not all plans discuss building ventilation, all facility
managers for facilities leased from the General Services
Administration have conferred with that agency regarding
adequate ventilation. According to the OMS principal deputy
assistant administrator, in EPA-owned buildings for which the
EPA has administrative control, facility managers have taken the
measures recommended by the CDC.
Cleaning and Disinfecting
The CDC's Guidance for Cleaning and Disinfecting Public Spaces,
Workplaces, Businesses, Schools, and Homes provides the following
information related to cleaning and disinfecting facilities:
•	"Normal routine cleaning with soap and water will decrease
how much of the virus is on surfaces and objects, which
reduces the risk of exposure."
•	"Disinfection using EPA-approved disinfectants against COVID-
19 can also help reduce the risk. Frequent disinfection of
surfaces and objects touched by multiple people is
important/'
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reopening
increase how often
high-touch areas are
to be cleaned.
Source: OIG analysis of EPA data.
(EPA OIG image)
Key Takeaway:
Visitor access parameters varied
across the reopening plans and were
often not dependent on the phase, as
outlined in the EPA Return to the
Workplace: Employee Information
message.
•	"When EPA-approved disinfectants are not available,
alternative disinfectants can be used (for example, 1/3 cup of
bleach added to 1 gallon of water, or 70% alcohol solutions)."
Agency staff indicated that all plans refer to following CDC guidelines
for cleaning and disinfecting. Of the 13 reopening plans we evaluated,
however, only those for Regions 2, 8, and 9 increase—over
pre-pandemic cleaning standards—how often high-touch areas are
cleaned. All other locations state that they will disinfect such areas but
do not mention an increase in the frequency of cleaning. In addition,
even the locations that increase the frequency of cleaning do not
outline specific or consistent courses of action. For example, although
Region 4's reopening plan states that its facilities will be cleaned and
disinfected more often, it does not detail how or specify how often.
While Region 9's reopening plan states that "high-touch surfaces in
common areas, including elevators and elevator lobbies" in its main
facility will be cleaned three times per day, it only provides for daily
cleaning in other Region 9 facilities, with additional cleaning as
requested. Appendix C shows some of the location-specific variations
for cleaning and disinfecting.
Interaction with Visitors and Non-EPA Employees
The CDC's Interim Guidance states that employers could "adjust...
business practices to reduce close contact with customers" as one
strategy to maintain social distancing. The CDC's Interim Guidance also
states that agencies should "[a]lter your workspace to help workers
and customers maintain social distancing and physically separate
employees from each other and from customers, when possible." In
addition, according to the EPA Return to the Workplace: Employee
Information message, visitor access to EPA facilities will generally be
controlled by phase:
•	Phase 1. No visitors are allowed.
•	Phase 2. Visitors are allowed for mission-essential reasons and
must conduct a self-assessment prior to entering the facility.
•	Phase 3. Visitors are not restricted.
We noted, however, that visitor access parameters varied across the
reopening plans and were often not dependent on the phase. For
instance, regardless of the reopening phase, Cincinnati's reopening
plan permits visitors to access the facility's credit union by
appointment, while the EPA headquarters' reopening plan allows
visitors if there is a "statutory, legal, or emergency requirement."
See Appendix D for other differences.
In response to our findings, the OMS principal deputy assistant
administrator informed us that the "'visitor access parameters' for all
locations follow the national guidance developed and issued by the
OMS. Local application of the national guidance may result in
differences depending on the facility (e.g. labs)."
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reopening plans
mention public
transportation
Source: OIG analysis of EPA data
(EPA OIG image)
Seven of the 13 EPA offices we reviewed are colocated with other
entities in the same building and share common areas, such as
elevators, with the general public: Regions 1, 2, 3, 6, and 9; Cincinnati;
and headquarters. These seven offices are open to the general public,
who access places such as credit unions, bankruptcy courts,
immigration courts, the Internal Revenue Service, and more. None of
the plans for these seven locations discuss how the Agency plans to
reduce close contact and interaction with the public.
Public Transportation
The CDC's Interim Guidance states that agencies should consider
offering support to employees who commute to work using public
transportation, including offering "incentives to use forms of
transportation that minimize close contact with others" and "allowing
employees to shift their hours so they can commute during less busy
times."
Even though ten of the 13 reopening plans we reviewed mention
public transportation, which many employees rely on to travel to and
from their offices, eight of those plans mainly address the availability
of public transportation and not the risks associated with potential
exposure to SARS-CoV-2 during the commute to work. In response to
our findings, the Agency indicated that in a June 11, 2020 message,
Administrator Wheeler outlined Agency guidance regarding mass
transit, although it too is focused on availability, not risk:
In Phase 3 we will also consider the availability of mass transit and extend
unscheduled telework for offices if mass transit during normal operating
hours is significantly impaired. I know that for many of our offices mass
transit can be the major, if not the sole, source of transportation for
employees. If there are ongoing interruptions of service which materially
impact the ability of employees to travel to work, we will adjust including
allowing for enhanced telework.
Agency Reopening Strategy Allows Flexibility
According to the OMS chief of staff, the agencywide reopening
strategy was not prescriptive but instead provided overarching
guidance, leaving each EPA location to determine its own protections
based on local conditions. Indeed, Memorandum M-20-23, issued
jointly by the Office of Management and Budget and the Office of
Personnel Management, states:
Federal government-wide operating decisions will be informed by states'
phasing assessments and conditions, but implemented at the direction of
agency heads or as delegated by the agency head... Agencies shall
review the relevant CDC and U.S. Department of Labor (DOL) guidance,
as well as other appropriate resources, when developing and
implementing new or modified policies and processes... on the availability
of hygiene supplies, facilities cleanliness, and social distancing. In
addition, agencies should institute other policies to enforce social
distancing and mitigation measures.
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Key Takeaway:
Location-based reopening plans
should offer consistent health and
safety measures in compliance with
the CDC's Interim Guidance.
Key Takeaway:
The EPA should determine whether
the location-specific reopening plans
should be revised to address the
differences in how they implement
health and safety measures.
Given the severity of the pandemic crisis and the risks associated with
the COVID-19 disease, it is imperative employees are assured that the
Agency has developed solid plans and that the rules and conditions at
all locations will be communicated transparently, implemented
consistently, and enforced effectively. As such, the OIG plans to
conduct further work in this area as Agency locations advance to
Phase 3 in the reopening process.
Conclusion
Providing a safe working environment for employees returning to their
physical work locations is a significant challenge facing the EPA as it
reopens its facilities. Although the location-specific reopening plans we
reviewed incorporate elements of the CDC's Interim Guidance, the
specific health and safety measures outlined in the plans often vary.
While some differences in the reopening plans could be warranted
based on local conditions, the EPA should ensure that such differences
do not place employees at an increased risk of contracting or
spreading the COVID-19 disease merely as a result of their work
location.
Recommendation
We recommend that the assistant administrator for Mission Support:
1. Determine, as Agency locations advance to Phase 3, whether
the EPA's location-specific reopening plans should be revised
to address differences in how they implement health and
safety measures.
Agency Comments and OIG Assessment
The Agency concurred with our recommendation and provided an
acceptable corrective action with an estimated completion date. EPA's
response states, "Specifically, OMS will work with regions and national
program managers to review the supplemental, location-specific
Reopening Plans for Phase 3 to ensure that they comply with the
Agency Phase 3 guidance, establish unique social distancing plans
tailored to the needs of the organization and facility, and provide
consistency in health and safety measures, while recognizing that
some flexibility is needed given the difference in ownership, use, and
ages of Agency buildings." See Appendix A. The Agency, however,
disagreed with some of the facts reflected in our report. We
considered its comments and revised the report as appropriate.
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Appendix A
Agency Response to Draft Report

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
November 17, 2020
OFFICE OF MISSION SUPPORT
MEMORANDUM
SUBJECT: Response to Office of Inspector General Draft Report No. OA&E-FY20-0241
"EPA's Initial Plans for Returning to the Office Incorporate CDC Guidance but
Differ by Location "
Thank you for the opportunity to respond to the subject audit report. The following summarizes
the agency's overall position, along with its position on the report recommendation with
additional background information. For the report recommendation with which the agency
agrees, we have provided a high-level intended corrective action with completion date. For your
consideration, we have included a Technical Comments Attachment to supplement this response.
AGENCY'S OVERALL POSITION
The Office of Mission Support understands that the Office of Inspector General's
recommendation is aimed at ensuring that the Agency's national strategy for implementing
federal guidelines to protect the health and safety of its workforce mitigates agency wide risks as
it plans to reopen facilities that were closed due to the coronavirus pandemic. While the Agency
does have concerns with some of the findings and content in the OIG's draft report on the subject
audit, as reflected in the Technical Comments Attachment, we agree with the OIG's
recommendation and found that this recommendation is currently being addressed by Agency
senior management.
Specifically, on July 16, 2020, the Agency issued supplemental guidance that recognizes
returning to the office in Phase 3 would not be under normal circumstances. The July guidance
includes the need for continued social distancing and flexibilities for certain communities. OMS
is working through the implementation of this guidance with the regions and national program
managers. The goal is to provide consistency in health and safety actions while recognizing that
some flexibility is needed given the difference in ownership, use and ages of our buildings.
FROM: Donna J. Vizian, Principal Deputy Assistant Administrator
TO:
Michael D. Davis, Director
Efficiency Directorate
Office of Audit and Evaluation
Office of Inspector General
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We trust that our effort to clarify some of the facts of the Agency's overall reopening plan and
the perceived disparity among the 13 reopening plans in question, along with our description of
actions we plan to take with Phase 3 plans, will bridge the remaining differences.
AGENCY'S RESPONSE TO REPORT RECOMMENDATIONS
Agreements
No.
Recommendation
High-Level Corrective Action(s)
Estimated
Completion
Date
1
Determine, as Agency
locations advance to
Phase 3, whether the
EPA's location-specific
reopening plans should be
revised to address
differences in how they
implement health and
safety measures.
OMS will determine, as Agency locations
advance to Phase 3, whether the EPA's
location-specific reopening plans should be
revised to address differences in how they
implement health and safety measures.
Specifically, OMS will work with regions and
national program managers to review the
supplemental, location-specific Reopening
Plans for Phase 3 to ensure that they comply
with the Agency Phase 3 guidance, establish
unique social distancing plans tailored to the
needs of the organization and facility, and
provide consistency in health and safety
measures, while recognizing that some
flexibility is needed given the difference in
ownership, use, and ages of Agency buildings.
Dec 1, 2020
CONTACT INFORMATION
If you have any questions regarding this response, please contact Michell Hauser of the Office of
Resources and Business Operations, at (202) 564-7636 or hauser.mitchell@epa.gov.
Attachment
cc: Katherine Trimble
James Hatfield
Michael D. Davis
Heather Layne
Juliana Ilieva
Detravion White
Lynnann Hitchens
Marilyn Braxton
David Zeckman
Daniel Coogan
Jan Jablonski
Monisha Harris
Marilyn Armstrong
Mitchell Hauser
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Appendix B
Scope and Methodology
To answer our objective, we interviewed the OMS chief of
staff to obtain an understanding of the Agency's efforts and
decisions related to the development of its location-based
reopening plans. We met and discussed our findings with the
OMS principal deputy assistant administrator and OMS staff.
We also provided the Agency an advanced copy of the final
report prior to issuance.
We reviewed the reopening plans for 13 EPA locations:
•	Headquarters (Washington, D.C., and
Potomac Yards, Virginia).
•	Research Triangle Park, North Carolina.
•	Cincinnati, Ohio.
•	Regions 1-10.
We selected these 13 locations because they are the primary
EPA locations where most staff work. Since these locations
continued to enter new phases during our fieldwork, we
based our findings on the EPA's plans and status as of
August 7, 2020.
We also reviewed the Agency's EPA Facility Status Dashboard
for the status of EPA locations during our evaluation period.
The last time the Agency updated its dashboard before we
ended our fieldwork was on August 5, 2020. As of that date,
one of the 13 locations we evaluated remained closed, two
were in Phase 0, eight were in Phase 1, and two were in
Phase 2. Since none of these 13 locations entered Phase 3 by
the end of our fieldwork, we focused on Phases 1 and 2 for
our evaluation. The table at the end of this appendix provides
more information on these 13 iocations and their reopening
progress.
We analyzed the Agency's national strategy for reopening
facilities, the reopening plans at the 13 locations we
reviewed, and applicable supplementation information for
consistency with the related guidance issued by the Office of
Management and Budget, the Office of Personnel
Management, and the CDC. To facilitate our review, we
developed a checklist based on the CDC's Interim Guidance
and the Occupational Safety and Health Administration's
Guidance on Preparing Workplaces for COVID-19. We
focused our review on the CDC's Interim Guidance because
Locations we reviewed
. ny
'Chicago	Philadelphia
San Francisco
Source: EPA data. (EPA OIG image)
Reopening phases for the 13 EPA locations
we reviewed
Closed:
1 facility
Phase 0:
Phase 3: |*j 2 facilities
0 facilities
Phase 2:
2 facilities
Number of
facilities by
phase
Phase 1:
8 facilities
^RPhase 0: 7-Day Closure Period
EPhase 1: Facility open, telework encouraged,
expanded work schedule
PPhase 2: Return to normal work schedule
with telework encouraged
PPhase 3: Return to normal work status
^Pciosed
Source: OIG analysis of EPA Facility Status
Dashboard data as of August 5, 2020.
(EPA OIG image)
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the EPA's New Guidance on Returning to the Workplace referred to the "Agency's adoption of the CDC's
guidance for businesses, including recommended strategies for those that are resuming normal or phased
business operations."
Since announcing our evaluation on July 1, 2020, we received eight OIG Hotline complaints and 12 letters of
concern from EPA staff and regional labor union representatives. Many of these hotline complaints and letters
of concern relate to the criteria that the EPA is using to reopen facilities. However, this report addresses the
consistency of the Agency's reopening plans with governmentwide guidance on reopening the workplace, not
the criteria that the EPA uses to decide when to reopen a location or advance a location to the next reopening
phase.
As more EPA locations reopen and advance to Phase 3, we plan to conduct further work and review the EPA's
implementation of health and safety measures.
Location Status
Location
Date location entered each phase
Phase 0
Phase 1
Phase 2
Cincinnati
June 15, 2020
August 4, 2020
-
Headquarters
June 15, 2020
June 23, 2020
August 4, 2020
Research
Triangle Park
August 10, 2020
-
-
Region 1
June 1, 2020
June 23, 2020
August 4, 2020
Region 2
June 22, 2020
June 30, 2020
-
Region 3
June 15, 2020
June 23, 2020
-
Region 4
May 21, 2020
May 28, 2020
-
Region 5
June 15, 2020
June 23, 2020
-
Region 6
June 1,2020
-
-
Region 7
May 22, 2020
May 29, 2020
-
Region 8
June 1, 2020
June 9, 2020
-
Region 9
-
-
-
RegionIO
May 21,2020
May 29, 2020
-
Source: OIG analysis of EPA Facility Status Dashboard data as of August 5, 2020 and facility
reopening plans as of August 7, 2020. (EPA OIG table)
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Appendix C
Differences in Regional Reopening Plans During Phases 1 and 2
Location
Face
coverings
(common
areas)
Social
distancing
Public
transportation a
Disinfecting
(common
areas)
Staggered
work shifts
Elevators
Rest room
limits
Building
ventilation
system
Cincinnati
Required
Required
Mentioned
Daily
disinfection
Suggested
Two people
Signage
Per CDC
Headquarters
Required
Required
Mentioned
Daily
disinfection
Suggested
Two people
Two people
No mention
Research
Triangle Park
Required
Required
Mentioned
Per CDC
Suggested
Signage
Signage
No mention
Region 1
Required
Per CDC
Mentioned
Disinfect
throughout
day
Expanded
hours
Two people
Signage with
occupancy
limits
Per CDC
Region 2
Required
Per CDC
Mentioned
Frequent
Disinfection
Expanded
hours
Two people
Three people
Per CDC
Region 3
Required
Required
Mentioned
Daily
cleaning
Will be
instituted
Three people
Three people
Thorough
cleaning of
HVAC*
system and
components
Region 4
Required
Suggested
No mention
Daily
cleaning
Expanded
hours
Two people
Two people
Per CDC
(email notice)
Region 5
Required
Encouraged
Mentioned
Daily
cleaning
Will be
instituted
Signage
Two people
Confer with
General
Services
Administration
Region 6
Recommended
Required
Mentioned
Daily
cleaning
Wll be
instituted
Four people
Two to three
people
Confer with
General
Services
Administration
Region 7
Recommended
Expected
No mention
Per CDC
Suggested
One person
Three people
Clean and test
operation
Region 8
Required
Encouraged
No mention
Increase
cleaning
Suggested
Two people
One person
No mention
Region 9b
Required
Required
Mentioned
Varies
between
buildings0
Wll be
instituted
Varies
between
buildingsd
Varies
between
buildings6
Maximize
outside air in
system
Region 10
Required
Required
Mentioned
Per CDC
Expanded
hours
Two People
One to two
people
depending on
size
Maximize
outside air in
system;
replace
MERV13
filters with
preferred
MERV14
filters
Source: OIG analysis of reopening plans and reopening information as of August 5, 2020. (EPA OIG table)
* Note: HVAC stands for "heating, ventilation, and air conditioning."
a Public transportation includes carpools, vanpools, buses, trains, and subways.
b Cleaning and disinfecting protocols are specific to each facility within Region 9, with additional guidelines and exceptions for each office.
0 At Region 9's main facility (the Hawthorne facility), cleaning will occur three times per day. The laboratory facilities will be cleaned
before and after use. At all other facilities, common-use areas will be wiped down before and after touching using EPA-supplied cleaning
products.
d At the Hawthorne facility: two people. At all other facilities: maintain social distancing.
e At the Hawthorne facility: one person. At all other facilities: maintain social distancing.
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Appendix D
Visitors Access Parameters: Based on Location and Phase
Location
Phase 1
Phase 2
Visitor screening
Cincinnati
Allowed to credit union
Mission essential
Self-assessment
Headquarters
Emergency only
Mission essential
Self-assessment
Research Triangle Park
Emergency only
Mission essential
Self-assessment
Region 1
Not allowed
Mission essential
Self-assessment
Region 2
Not allowed
Mission essential
Self-assessment
Region 3
Not allowed*
Varies by location
No mention
Region 4
Not allowed
Mission essential
No mention
Region 5
No non-EPA visitors
Allowed**
Self-assessment
Region 6
No non-EPA visitors
5th floor only
Self-assessment
Region 7
Not allowed
Mission essential
No mention
Region 8
Not allowed
No mention
No mention
Region 9
Not allowed
Essential visitors
No mention
Region 10
Not allowed
Mission essential
No mention
Source: OIG analysis of reopening plans and reopening information. (EPA OIG table)
* Per May 21, 2020 email to staff, "No visitors in Phase 1
** "Visitors may be allowed in EPA workspace, where consistent with GSA building access requirements."
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Appendix E
Status of Recommendations and
Potential Monetary Benefits
RECOMMENDATIONS






Potential






Monetary
Rec.
Page



Planned
Benefits
No.
No.
Subject
Status 1
Action Official
Completion Date
(in $000s)
1 10 Determine, as Agency locations advance to Phase 3, whether R Assistant Administrator for 12/1/20
the EPA's location-specific reopening plans should be revised	Mission Support
to address differences in how they implement health and
safety measures.
1 C = Corrective action completed.
R = Recommendation resolved with corrective action pending.
U = Recommendation unresolved with resolution efforts in progress.
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Distribution
The Administrator
Assistant Deputy Administrator
Associate Deputy Administrator
Chief of Staff
Deputy Chief of Staff/Operations
Agency Follow-Up Official (the CFO)
Assistant Administrator for Mission Support
Regional Administrators, Regions 1-10
Agency Follow-Up Coordinator
General Counsel
Associate Administrator for Congressional and Intergovernmental Relations
Associate Administrator for Public Affairs
Principal Deputy Assistant Administrator for Mission Support
Associate Deputy Assistant Administrator for Mission Support
Deputy Regional Administrators, Regions 1-10
Director, Office of Continuous Improvement, Office of the Administrator
Director, Office of Resources and Business Operations, Office of Mission Support
Director, Office of Regional Operations
Audit Follow-Up Coordinator, Office of the Administrator
Audit Follow-Up Coordinator, Office of Mission Support
Audit Follow-Up Coordinators, Regions 1-10
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