24-N-0010
December 6, 2023

At a Glance

The CSB's Fiscal Year 2024 Top Management Challenges

What Are Management
Challenges?

The Reports Consolidation Act of 2000
requires each inspector general to
prepare an annual statement
summarizing what the inspector
general considers to be "the most
serious management and performance
challenges facing the agency" and to
briefly assess the agency's progress in
addressing those challenges.

Our previous U.S. Chemical Safety and
Hazard Investigation Board report.
Fiscal Year 2023 U. S. Chemical Safety
and Hazard Investigation Board
Management Challenges, issued
October 21, 2022, identified three top
management challenges facing the
agency. Those challenges addressed
operating effectively without a full
board, minimizing mission-critical staff
vacancies and attrition rates, and
improving cybersecurity. We have
retained these challenges for fiscal
year 2024. In addition, we have
identified the promotion of ethical
conduct as a new top management
challenge for the CSB.

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.PublicAffairs@epa.gov.

What We Found

We retained the three previously identified top management and performance challenges
from the prior year's report, and we added a fourth challenge. We consider these to be the
CSB's greatest vulnerabilities to waste, fraud, abuse, and mismanagement and the most
significant barriers to accomplishing the CSB's mission during fiscal year 2024:

1.	Management Challenge (initially identified in fiscal year 2019):

Operating effectively without a full board.

The CSB's governing board has only three confirmed members, one more than when
we highlighted this challenge in fiscal year 2023. The Clean Air Act Amendments of
1990 authorized the creation of the CSB and established a board of five members,
including a chairperson. That board is responsible for major budgeting decisions,
strategic planning and direction, general oversight of the CSB, and approval of
investigation reports and studies. The lack of a full board has inhibited the CSB's
mission to conduct investigations to protect people and the environment. A full board
ensures that the CSB can function in the event of the loss of one or two board
members.

2.	Management Challenge (initially identified in fiscal year 2023):

Minimizing mission-critical staff vacancies and attrition rates.

The CSB is working to increase hiring, but vacancies and attrition rates remain a
concern. As of the end of September 2023, the CSB's staffing level was short of fiscal
year-end projections by ten full-time equivalents, or about 20 percent. Mission-critical
positions have remained vacant for more than one year. Despite some improvements,
we remain concerned that staffing problems affect the CSB's ability to carry out day-
to-day operations in a timely manner, including deployment to new incidents,
completion of investigations, and issuance of reports.

3.	Management Challenge (initially identified in fiscal year 2023):

Improving cybersecurity.

The CSB has demonstrated a strong commitment to its cybersecurity program and to
addressing the Office of Inspector General's cybersecurity recommendations to
ensure the reliability, availability, and accuracy of CSB data. However, the CSB
should ensure that it has formalized and documented policies, procedures, and
strategies for its information security program and that they are consistently
implemented. The risk that vulnerabilities may be exploited is elevated at the CSB's
latest assessed information security level. The CSB's continued improvement to its
cybersecurity posture and increased maturity level is necessary to fully address prior
Office of Inspector General recommendations.

4.	Management Challenge (new): Promoting ethical conduct.

In July 2023, the U.S. Office of Government Ethics recommended that the CSB take
steps to improve its ethics program. The CSB is reviewing this recommendation and
plans to fully respond by January 2024. A robust ethics program, combined with
training, can assist employees in recognizing potential ethics concerns.

List of OIG reports.


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