x-^tD S7>]p. ° *. U.S. Environmental Protection Agency 21-P-0131 i W \ Office of Inspector General May 12,2021 At a Glance Why We Did This Audit As a result of an OIG Hotline complaint, we conducted an audit of the U.S. Environmental Protection Agency's Office of Enforcement and Compliance Assurance, specifically, the Office of Criminal Enforcement, Forensics, and Training and its National Enforcement Investigations Center. We conducted this audit to determine whether OCEFT and NEIC are addressing findings and implementing corrective actions from prior internal and external audits, inspections, and documented concerns related to NEIC. OCEFT is a federal law enforcement entity that pursues criminal violators of air, water, and hazardous waste pollution laws. NEIC provides forensic, scientific, and technical support for EPA criminal and civil environmental investigations. This audit addresses the following: • Operating efficiently and effectively. This audit addresses a top EPA management challenge: • Improving workforce/workload analyses. Address inquiries to our public affairs office at (202) 566-2391 or OIG WEBCOMMENTS@epa.gov. List of OIG reports. Staffing Constraints, Safety and Health Concerns at EPA's National Enforcement Investigations Center May Compromise Ability to Achieve Mission Safety, health, and attrition issues may compromise NEIC's ability to support the EPA's civil and criminal enforcement efforts. What We Found NEIC has addressed internal and external findings and implemented corrective actions related to safety and health, yet concerns persist. These concerns include unconducted internal safety and health audits and management reviews, hazardous waste mismanagement, noncompliance with safety procedures, and staff concerns about safety and health at NEIC. NEIC is addressing findings and implementing corrective actions related to its Quality Management System, which is designed to generate scientifically sound and legally defensible information to support environmental enforcement. We found that NEIC should improve tracking issues, such as observations, comments, concerns, and opportunities for improvement identified from audits; management review action items; and customer complaints. NEIC had unresolved action items from OCEFT's Professional Integrity and Quality Assurance unit's 2017 inspection report related to staffing shortages, trust in management, and hazardous waste management. OCEFT did not conduct a follow-up review to examine the effectiveness of the implemented corrective actions. In 2020, as a result of an inspection by the State of Colorado, NEIC was cited for several hazardous waste violations. Further, NEIC's 2019 Federal Employee Viewpoint Survey results are 22 percent lower than the EPA's averages for questions related to management and work environment. NEIC has been challenged by high attrition rates among staff and the inability to backfill vacant positions since 2016. If staffing levels continue to fall, NEIC risks a reduction in analytical capabilities and the ability to accomplish its mission. Recommendations and Planned Agency Corrective Actions We made ten recommendations to the assistant administrator for Enforcement and Compliance Assurance, including developing a process for OCEFT to follow up on inspection findings and confirm whether corrective actions effectively address findings, as well as developing metrics on safety, health, and work environment to incorporate into NEIC management performance evaluations. The Agency agreed with seven recommendations and disagreed with three recommendations. We consider three recommendations resolved, two completed, and five unresolved. The Agency's response to our draft report illustrates that it does not fully understand or appreciate federal Office of Inspector General audit processes and standards. We stand by our conclusions and recommendations. ------- |