EVALUATION 

EVALUATION OF 

USGS SCIENTIFIC COLLECTION 

MANAGEMENT POLICY 

Report No.: 2016-ER-057 September 2017
OFFICE OF 


INSPECTOR GENERAL 


U.S.DEPARTMENT OF THE INTERIOR 

Memorandum 

To: 	 Amy Holley 

Acting Assistant Secretary for Policy, Management and Budget 

William Werkheiser 

From: 	 Mary L. Kendall 

Deputy Inspector Gene 

Subject: 	 Final Evaluation Report - Evaluation of USGS Scientific Collection Management 

Policy 

Report No. 2016-ER-057 

The Office oflnspector General reviewed the current policies of the U.S. Geological 

Survey (USGS) for managing its scientific collections. Specifically, we reviewed these policies 

for consistency with established U.S. Department of the Interior (DOI) policies and compared 

them with those of two other bureaus-the National Park Service (NPS) and U.S. Fish and 

Wildlife Service (FWS). We found that USGS scientific collection management policies are not 

consistent with DOI policies as defined in the Department Manual (DM) and are not comparable 

to policies of the other two bureaus. In addition, we found that USGS did not have a final policy 

on the management of its biologic specimens; therefore, we could not review this policy for 

consistency with the OM. 

This report provides the findings of our evaluation and offers one recommendation to 

USGS to adjust its policies to be consistent with the OM to ensure the USGS protects and 

preserves valuable scientific specimens. 

Background 

DOI bureaus collectively manage a variety of historic, biologic, and geologic objects that 

all fall under the umbrella of scientific collections. These collections are further categorized as 

being "museum" or "working" collections in the DOI policies found in the DM. One difference 

between the two types lies in the rules for the long-term preservation of the artifacts within the 

collection: museum collections are retained for long-term preservation and study, while working 

collections are not subject to such stringent preservation requirements. 

A former USGS employee and a nonprofit organization have criticized USGS collections 

management policies. OIG received three requests to review USGS policies and procedures. The 

Office of Inspector General I Washington, DC 
2

requests alleged that USGS uses misleading language and terms to improperly categorize 

collections as working collections for use in research, potentially allowing the USGS to avoid 

DM requirements for the preservation of specimens that otherwise would be maintained as 

museum collections. The NPS and FWS, whose policies align with the DM, preserve most of 

DOI’s museum artifacts (see Figure 1). 

Bureau Number of Museum Objects

Preserved

NPS 167,012,704

FWS 4,517,955

USGS 52,506

Figure 1: Number of museum objects maintained by select bureaus, drawn from fiscal year 2014 data.

Scope and Methodology

We conducted our review in 2016–2017 and focused on Department and bureau policies 

related to museum collections. To accomplish our objectives, we obtained a general 

understanding of departmental standards for the management of scientific collections, and 

interviewed officials from the DOI and USGS. We also reviewed policies from the DOI, USGS, 

NPS, and FWS, and compared USGS policies with them to determine whether they were 

consistent with each other.

Evaluation Results

We found that USGS’ scientific collection management policies are not consistent with 

DM policies and are not comparable to policies of other bureaus. In addition, we found that 

USGS did not have a final policy to address its biologic specimens; therefore, we could not 

review this policy for consistency with the DM.

USGS’ policy uses language that differs from the language set forth in Part 411 of the 

DM. Rather than match the naming conventions for collections that the DM uses, such as 

“museum collection” and “working collection,” USGS policy uses the terms “resource 

collection” to describe items to be preserved indefinitely, and “active” collection for material 

from ongoing research. It has also publicly documented its intent to limit the growth of 

collections maintained indefinitely to curtail future maintenance costs. 

USGS has also cited adherence to the requirements of Title 20 of the United States Code

(U.S.C.), Section 59 as its reason for aligning its policy language with that of the Smithsonian 

Institution rather than with the DM. USGS’ stance does not appear to account for the potential 

applicability of other statutory authorities. The differing museum authorities have led to the 

USGS not complying with DOI policy, which could result in the destruction or loss of specimens 

that any other bureau would be required to preserve. 

When compared to the NPS and FWS, which manage nearly 88 percent of the DOI’s 

museum objects, we found that policies for these bureaus were similar to each other, and that 
3 

each bureau used the DM as a starting point for developing its policies in a way that expanded on 

the DM requirements rather than departed from it. Because of the consistency in policy shown 

between these two bureaus, USGS’ dissimilar policy appears to represent an intentional 

departure from the DM. 

In addition, the USGS policy only applies to collections of geologic specimens. The 

USGS has stated that it is developing a policy for biologic specimens, but has not yet issued it. 

The use of different terminology, as well as the absence of a policy for biologic specimens, could 

result in the loss or destruction of otherwise valuable specimens. 

Conclusion and Recommendation

USGS scientific collection policy and absence of policy allow the USGS to exclude its 

collections from preservation requirements prescribed by the DM. The different authorities noted 

have led to confusion that could leave valuable scientific specimens—that may otherwise be 

candidates for long-term preservation—at risk of loss or destruction. 

We recommend that USGS— 

1. Reconcile and justify current and future scientific collection policies with the 

requirements of the Departmental Manual. 

USGS response and OIG analysis: Although the USGS stated that its current policy 

aligns with the DM requirements for managing scientific collections, our results 

suggest otherwise. As noted previously in this report, USGS policy uses language that 

is inconsistent with the DM naming conventions for its collections, and the current 

USGS policy only addresses the geologic collections and not USGS’s biologic 

collections. In its response, USGS stated that it is in the process of developing new 

policy and implementation guidelines and procedures that will align its scientific 

collections with the DM requirements. The target completion date for that policy is 

September 30, 2018. We consider this recommendation resolved but not 

implemented, and will refer it to the Assistant Secretary for Policy, Management and 

Budget for tracking.

The legislation creating the Office of Inspector General requires that we report to 

Congress semiannually on all audit, inspection, and evaluation reports issued; actions taken to 

implement our recommendations; and recommendations that have not been implemented. 

We conducted our evaluation in accordance with the Quality Standards for Inspection and 

Evaluation as put forth by the Council of the Inspectors General on Integrity and Efficiency. We 

believe that the work performed provides a reasonable basis for our conclusions and 

recommendations. 

Attachment
Attachment

United States Department of the Interior 

U.S. GEOLOGICAL SURVEY 
 

Office of the Director 
 

Reston, Virginia 20192 
 

Memorandum 	 AUG 0 2 2017 

To: 	 Mary L. Kendall 

Deputy Inspector General 

Through: 	 

Acting 

Andrea 

Assistant 

Travnicek 

Secretary for 

~~ 

Water and Science 

From: 	 William H. Werkheiser 0-t.-J I// j tJ j (\ _ Actmg Director l[Zrf 

Subject: 	 Office of the Inspector General (OIG) Draft Evaluation Report - Evaluation of 

USGS Scientific Collection Management Policy, Report No. 2016-ER-057 

In the subject report, dated June 2017, the OIG of the Department of the Interior (DOI) 

reviewed the current policies of the U.S. Geological Survey (USGS) for managing its 

scientific collections. The OIG found that the USGS scientific collection management 

policies are not consistent with DOI policies as defined in the Department Manual (DM) and 

are not comparable to policies of two other bureaus--the National Park Service (NPS) and the 

U.S. Fish and Wildlife Service (FWS). In addition, the OIG found that the USGS did not 

have a final policy on the management of its biologic specimens, which meant the OIG could 

not review such policy for consistency with the DM. 

OIG Recommendation: Reconcile and justify current and future scientific collection 

policies with the requirements of the Departmental Manual. 

Response: It is the perspective of the USGS that its scientific collection policy is in 

alignment with the Departmental Manual requirements for working scientific collections. 

Specifically, it aligns with the DM Part 411. Chapter 3, Section lb, which provides the 

following language: ''Non-Museum Property- Working Collections. A bureau may decide 

that working scientific collections will not be managed as museum property. " 

The USGS policy applies to the management of scientific collections. By contrast, the NPS 

and FWS policies apply to the management of museum collections. The language used to 

describe USGS scientific collections is well aligned with that of other science agencies, such 

as NASA (NASA Policy Directive, NPD 7100. l OF) and the U.S. Department of Agriculture 

(USDA) Agricultural Research Service (ARS) (USDA ARS Scientific Collections 

Management and Access Policy September 2014). 
2 

The USGS scientific collections policy employs terminology promulgated by the White 

House Office of Science and Technology Policy (OSTP) and the National Science and 

Technology Council Interagency Working Group for Scientific Collections (IWGSC), in 

accordance with U.S Code, Title 42, Chapter 79, Subchapter II, Section 6624, the OSTP 

Memorandum ofMarch 20, 2014: Improving the Management of and Access to Scientific 

Collections, and the IWGSC report: Scientific Collections: Mission-Critical Infrastructure 

for Federal Science Agencies. 

By the Sundry Civil Act ofMarch 3, 1879 [20 USC§ 59], Congress explicitly separated the 

scientific investigation functions of "the Ocean Survey, the Geological Survey, or any other 

parties of the Government" from museum functions that it mandated to the National Museum 

[ofNatural History, Smithsonian Institution]. "All collections of rocks, minerals, fossils, and 

objects of natural history, archaeology and ethnology, made by the National Ocean Survey, 

the United States Geological Survey, or by any other parties of the Government of the United 

States, when no longer needed for investigation in progress shall be deposited in the National 

Museum." 

USGS Policy: 

The USGS is in the process of developing policy that will apply to all scientific collections, 

which will be constituted as a USGS Survey Manual Chapter. The policy will continue to 

align with the DM Part 411. Chapter 3, Section lb. The USGS will also develop 

implementation guidelines and procedures that will apply to all scientific collections including 

biological collections. 

Target Completion Date: September 30, 2018 

Responsible Official: Kevin Gallagher, Associate Director, USGS Core Science Systems 

Mission Area 

Ifyou have any questions, please contact Lindsay Powers at (303) 202-4828 or 

1powers@usgs.gov. 
Report Fraud, Waste,

and Mismanagement

Fraud, waste, and mismanagement in

Government concern everyone: Office 

of Inspector General staff, departmental 

employees, and the general public. We 

actively solicit allegations of any 

inefficient and wasteful practices, fraud, 

and mismanagement related to 

departmental or Insular Area programs 

and operations. You can report 

allegations to us in several ways.

 By Internet: www.doioig.gov

 By Phone: 24-Hour Toll Free: 800-424-5081

Washington Metro Area: 202-208-5300

 By Fax: 703-487-5402

 By Mail: U.S. Department of the Interior

Office of Inspector General

Mail Stop 4428 MIB

1849 C Street, NW.

Washington, DC 20240