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To Ensure Greater Use of 

Scientific Equipment, the 

Office of Research and 

Development Should Use

an Enterprise Approach to 

Property Management

Report No. 15-P-0115 March 16, 2015

U.S. ENVIRONMENTAL PROTECTION AGENCY

OFFICE OF INSPECTOR GENERAL

Science and Research
Report Contributors: Patrick Gilbride

Erin Barnes-Weaver

Todd Goldman

Raul Adrian

Derek Mulvihill

Abbreviations

CFR Code of Federal Regulations

EPA U.S. Environmental Protection Agency

NERL National Exposure Research Laboratory

NHEERL National Health and Environmental Effects Research Laboratory

NRMRL National Risk Management Research Laboratory

OIG Office of Inspector General

ORD Office of Research and Development

RTP Research Triangle Park

Cover photo: A plasma mass spectrometer in the EPA’s National Exposure Research 

Laboratory in Research Triangle Park, North Carolina. (EPA OIG photo)

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 15-P-0115

March 16, 2015

Why We Did This Review

We conducted this review to 

determine whether the 

U.S. Environmental Protection 

Agency (EPA) Office of 

Research and Development 

(ORD) has adequate controls 

over research equipment

utilized for decision-making.

Science provides the 

foundation for credible 

decision-making. As the 

scientific research arm of the

EPA, ORD uses sensitive and 

often expensive equipment. 

ORD’s reported capital 

equipment totals nearly 

$73 million. Property 

management regulations 

require that agencies identify 

and reassign any idle 

equipment and maintain 

adequate inventory controls 

and accountability systems. 

We reviewed usage of a 

sample of 99 pieces of 

scientific equipment in three 

national laboratories.

This report addresses the 

following EPA goal or 

cross-agency strategy:

 Embracing EPA as a highperforming organization.

Send all inquiries to our public 

affairs office at (202) 566-2391

or visit www.epa.gov/oig.

The full report is at:

www.epa.gov/oig/reports/2015/ 

20150316-15-P-0115.pdf

 

To Ensure Greater Use of Scientific Equipment, 

the Office of Research and Development Should Use 

an Enterprise Approach to Property Management

 What We Found

Our review of a sample of research equipment 

within three laboratories found that approximately 

30 percent (or 30 of 99 pieces) had not been used

for 2 to 14 years, and 6 percent (or six of 99 pieces)

were obsolete. Equipment used for air and water 

research sat idle either because there was no 

ongoing research necessitating its use or because it was being kept as backup 

equipment. Laboratories did not comply with federal property regulations, which 

require equipment inspection walkthroughs every 2 years and the creation of 

equipment pools to maximize the use of idle equipment and identify obsolete pieces.

The EPA does not manage its scientific equipment as a business unit or enterprise. 

ORD managers and staff are not aware of federal property management 

requirements. While ORD established the position of a National Asset Manager, 

ORD has not created a comprehensive, officewide scientific equipment list that 

would make ORD’s resources visible throughout the agency for key research 

decision-making. Additionally, ORD does not have clear lines of authority for 

equipment accountability and usage. Program risks exist as a result, including 

valuable scientific equipment sitting idle when there might be a demand for it 

elsewhere in ORD or the agency. Additionally, ORD could waste funds by 

purchasing duplicative research equipment. To minimize risks, ORD should ensure 

compliance with applicable federal property regulations. Better property 

management would aid decision-making on the use of and need for risk

management and exposure research equipment, and would position ORD to rethink 

its equipment from an enterprise perspective.

 Recommendations and Planned Corrective Actions

We recommend that the Assistant Administrator for ORD develop an ORD 

equipment list, create an equipment pool, establish regular equipment utilization 

walkthroughs, and conduct independent reviews of equipment procedures. We also 

recommend that the Assistant Administrator define the role and authority of the 

National Asset Manager, and excess obsolete equipment identified during our site 

visits. ORD suggested additional wording for our first recommendation, which we 

accepted. ORD agreed with all recommendations, which are resolved and open with 

corrective actions pending.

 Agency Actions Prompted by OIG Work

ORD’s National Asset Manager started developing an ORD-wide list of capital 

equipment, and two laboratories started identifying idle equipment to excess.

U.S. Environmental Protection Agency

Office of Inspector General

At a Glance

By not effectively 

managing property, 

30 percent of a sample of 

scientific equipment sat 

idle in three laboratories.
March 16, 2015

MEMORANDUM

SUBJECT: To Ensure Greater Use of Scientific Equipment, the Office of Research and 

Development Should Use an Enterprise Approach to Property Management

Report No. 15-P-0115

FROM: Arthur A. Elkins Jr.

TO: Lek Kadeli, Acting Assistant Administrator

Office of Research and Development

This is our report on the subject evaluation conducted by the Office of Inspector General (OIG) of the 

U.S. Environmental Protection Agency (EPA). This report contains findings that describe the problems 

the OIG has identified and corrective actions the OIG recommends. This report represents the opinion of 

the OIG and does not necessarily represent the final EPA position. EPA managers, in accordance with 

established audit resolution procedures, will make final determinations on matters in this report.

The EPA offices with primary responsibility over the issues discussed in this report include the 

laboratories within the Office of Research and Development as well as the Office of Administrative and 

Research Support, which houses the National Asset Manager. Additionally, the EPA’s Office of 

Administration and Resources Management administers the personal property management program.

Action Required

You are not required to provide a written response to this final report because you provided agreed-to 

corrective actions and planned completion dates for the report recommendations. The OIG may make 

periodic inquiries on your progress in implementing these corrective actions. Please update the EPA’s 

Management Audit Tracking System as you complete planned corrective actions. Should you choose to 

provide a final response, we will post your response on the OIG’s public website, along with our 

memorandum commenting on your response. You should provide your response as an Adobe PDF file 

that complies with the accessibility requirements of Section 508 of the Rehabilitation Act of 1973, as 

amended.

We will post this report to our website at http://www.epa.gov/oig.

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C. 20460

THE INSPECTOR GENERAL
To Ensure Greater Use of Scientific Equipment, 15-P-0115

the Office of Research and Development Should Use 

an Enterprise Approach to Property Management

Table of Contents

Purpose...................................................................................................................... 1

Background ............................................................................................................... 1

Agency Actions Prompted by OIG Work ................................................................. 3

Responsible Offices.................................................................................................. 3

Scope and Methodology........................................................................................... 3

Results of Review ..................................................................................................... 6

Conclusion ................................................................................................................ 8

Recommendations .................................................................................................... 9

Agency Comments and OIG Evaluation .................................................................. 9

Status of Recommendations and Potential Monetary Benefits ............................. 10

Appendices

A Agency Response to Official Draft Report and OIG Comments.................... 11

B Distribution ....................................................................................................... 15
15-P-0115 1

Purpose

We conducted this review to determine whether the U.S. Environmental 

Protection Agency (EPA) Office of Research and Development (ORD) has 

adequate controls over research equipment—including safeguarding, 

maintenance, calibration and utilization—to ensure that equipment may be relied 

upon for EPA decision-making and reporting. During our review we decided to 

shift the focus from data reliability to equipment utilized for decision making.

Background

Science at the EPA provides the foundation for credible decision-making to 

safeguard human health and ecosystems from environmental pollutants. ORD is 

the scientific research arm of the EPA and its research helps provide the 

underpinning of science and technology for the agency. ORD conducts research in 

14 facilities across the country, including three national laboratories we reviewed:

 National Exposure Research Laboratory (NERL). NERL develops and 

applies innovations in exposure science (i.e., study of methods, 

measurements and models to assess and predict exposure of humans and 

ecosystems to harmful environmental stressors). Headquartered in 

Research Triangle Park (RTP), North Carolina, NERL conducts its work 

across six divisions in four geographic locations.

 National Health and Environmental Effects Research Laboratory 

(NHEERL). NHEERL serves as the agency’s focal point for scientific 

research on the effects of contaminants and environmental stressors on 

human health and ecosystem integrity. Also headquartered in RTP, 

NHEERL conducts work across seven divisions in eight locations.

 National Risk Management Research Laboratory (NRMRL).

NRMRL focuses on environmental problem-solving to determine what 

environmental risks exist and how to manage those risks to protect human 

health and the environment. Headquartered in Cincinnati, Ohio, NRMRL 

conducts its work in five divisions in four locations.

To accomplish its mission, ORD uses sensitive and often expensive laboratory 

and field testing equipment. ORD’s reported capital equipment—those pieces 

over $75,000—totaled nearly $73 million.1 ORD’s fiscal years 2013 and 2014 

Federal Managers’ Financial Integrity Act assurance letters list scientific 

equipment as a key area in internal control risk assessment protocols.

 

1 This amount reflects purchases through ORD’s Procurement and Acquisition of Capital Equipment system. The 

amount does not reflect any purchases over $75,000 that individual laboratories made on their own, nor does it 

include any scientific equipment valued at less than $75,000 (e.g., pipettes, balances).
15-P-0115 2

Additionally, ORD included annual equipment and physical property inventories 

as part of multi-year review plans. 

Within the past 2 years, ORD created a National Asset Management position. The 

National Asset Manager serves as the ORD-wide property liaison, coordinates 

annual equipment and property inventories, and facilitates property transfer or 

disposal throughout ORD. The National Asset Manager also indicated that each 

ORD laboratory division has officers for property management, accountability 

and utilization.

Federal property management regulations in the Code of Federal Regulations 

(CFR), at 41 CFR 101, include the following requirements:

Section

101-25.109-1

Federal laboratories must be inspected at least every 2 years to 

determine if any idle or unneeded equipment exists. Equipment 

identified as idle or unneeded shall be reassigned as needed within 

the laboratory, placed in an equipment pool, or declared excess and 

made available to other agencies.

Section

101–25.109–2

Federal laboratories shall establish equipment pools so that 

laboratory and research equipment can be shared or allocated on a 

temporary basis to laboratory activities and individuals whose 

average use does not warrant the assignment of the equipment on a 

permanent basis.2

Federal regulations at 41 CFR 101 also requires the agency head to ensure 

compliance and conduct periodic independent reviews to determine effectiveness 

and make modifications.3

Additionally, the Federal Property and Administrative Services Act requires that 

each agency:

1. Maintain adequate inventory controls and accountability systems for the 

property under its control.

2. Continuously survey property under its control to determine which is 

excess property, and promptly report such property to the administrator.4

3. Perform the care and handling of such excess property.

4. Transfer or dispose of such property as promptly as possible in accordance 

with authority delegated by and regulations prescribed by the 

administrator.

5

 

2 This section goes on to note that: “Where the establishment of a physical pool would be economically unfeasible 

due to excessive transportation and handling costs, limited personnel resources, or limited space, pooling may be 

accomplished by means of equipment listings.” Elsewhere in this report we describe the need for such a list.

3 Section 101-25.109-1(d).

4 The Act distinguishes excess and surplus property. Excess property is that no longer required by a federal agency, 

whereas surplus property is that no longer required by any federal agency. 40 U.S.C. §102(3), 40 U.S.C §102(10).

5 40 U.S.C. §524(a)(5).
15-P-0115 3

5. Make reassignments of property among activities within the agency when 

such property is determined to be no longer required for the purposes of 

the appropriation from which it was purchased.

6. Transfer excess property under its control to other federal agencies.

7. Obtain excess property from other federal agencies.6

EPA Policy 4832, Personal Property and Procedures Manual, describes the 

agency’s roles and responsibilities regarding personal property. The EPA’s Office 

of Administration and Resources Management administers the personal property 

management program but, outside headquarters, delegates specific responsibilities 

to Regional and Assistant Administrators. The agency’s personal property 

program is managed in the Compass Data Warehouse through 24 accountable 

areas based on geographic locations. For example, each ORD facility has its own 

accountable area. Overall responsibility for managing day-to-day property 

management activities resides with custodial officers7such as those at the ORD 

laboratory division level.

Agency Actions Prompted by OIG Work

As a result of our EPA Office of Inspector General (OIG) work, ORD’s National 

Asset Manager has started developing an ORD-wide list of capital equipment. In 

addition, two national laboratories started excessing idle equipment found during 

our site visits.

Responsible Offices

The EPA offices with primary responsibility over the issues discussed in this 

report include the laboratories we reviewed within ORD as well as the Office of 

Administrative and Research Support, which houses the National Asset Manager.

Additionally, as noted above, the EPA’s Office of Administration and Resources 

Management administers the personal property management program.

Scope and Methodology

We conducted our review from April 2014 to January 2015. We conducted this 

performance audit in accordance with generally accepted government auditing 

standards. Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our findings and 

conclusions based on our audit objectives. We believe that the evidence obtained 

provides a reasonable basis for our findings and conclusions based on our audit 

objectives.

 

6 40 U.S.C. §524(b)(3).

7 ORD fills custodial officer positions with laboratory staff. EPA’s Office of Administration and Resources 

Management staffs the property accountable and utilization officer positions.
15-P-0115 4

To address our objective, we reviewed relevant materials pertaining to the use, 

calibration, maintenance and safeguarding of scientific equipment, including 

applicable federal regulations and EPA policies and procedures. We interviewed 

key staff within ORD, the three national ORD laboratories in our scope, and the 

Office of Administration and Resources Management.

To test controls over ORD scientific equipment, we made two site visits. We first 

visited NERL, NHEERL and NRMRL facilities in RTP, North Carolina, given 

their close proximity to each other and high dollar value equipment within each 

laboratory (the three laboratories have 117 items each valued over $100,000). 

Next we visited NERL and NRMRL facilities in Cincinnati, Ohio, to test controls 

over equipment in a smaller facility. For each site visit, we used Compass Data 

Warehouse8information to develop judgmental samples of scientific equipment to 

review. Our samples included equipment with acquisition costs that ranged from 

$25,000 to $100,000 and equipment with costs over $100,000. We also randomly 

selected items while touring each laboratory.

 In RTP the sample included 49 pieces of equipment valued at $7.1 million:

o 11 pieces between $25,000 and $100,000.

o 27 pieces over $100,000.

o 11 randomly selected pieces that each had an acquisition cost of 

less than $25,000.

 In Cincinnati the sample included 50 pieces of equipment valued at 

$9.8 million:

o 19 pieces between $25,000 and $100,000.

o 29 pieces over $100,000.

o 2 randomly selected pieces that each had an acquisition cost of less 

than $25,000.

To test safeguarding, we observed that ORD housed all scientific equipment in 

our sample in secure locations (i.e., buildings had security guards, badges were 

required for building access, and rooms housing equipment were locked). To test 

maintenance, calibration and usage, we developed a standard template to review 

each piece of scientific equipment in our sample. For example, we checked 

equipment logs and other records to ensure that labs performed calibration and 

maintenance. Our calibration testing focused on equipment in Cincinnati where, 

after providing laboratory staff with an equipment list in advance, we saw 

evidence of calibration documentation for all actively used pieces in our sample. 

We could not opine on the quality of calibrations; rather, we determined whether 

they were conducted. Determining the quality of calibrations for data reliability 

would require a detailed assessment of quality assurance materials outside of our 

revised scope on equipment used for decision making. Regarding usage, our 

 

8 The Compass Data Warehouse is an electronic interface used to access two separate databases (Momentum and 

Maximo) housing the agency’s financial and property management data.
15-P-0115 5

testing determined the date equipment was last utilized. At the close of our 

testing, we queried individual laboratories to verify our sampling results and 

obtain justifications for any equipment not utilized in the past 2 or more years.

Three prior reports relate to our review:

 The first, issued in 2011 by the U.S. Government Accountability Office,9

found that the EPA had not taken an agencywide, coordinated approach to 

managing its scientific efforts and did not manage its laboratory facilities 

as part of an interrelated portfolio. It recommended, among other things, 

that the EPA develop a coordinated planning process for its scientific 

activities and improve physical and real property planning decisions 

across all laboratories. The EPA generally agreed with these findings and 

recommendations. The EPA said that, beginning in fiscal year 2011, the 

agency added coding to track operating costs at program-funded 

laboratory facilities not previously tracked. The EPA also said it would 

review options for improving data reliability and completeness for the 

remaining labs within its laboratory enterprise. Additionally, to address 

some of the recommendations, the EPA formed a cross-agency workgroup 

led by the Office of the Science Advisor. One initiative by this group was 

to commission the National Academy review mentioned in the next bullet.

 In September 2014, the National Academy of Sciences10 similarly 

observed how EPA laboratories could become more effective and efficient 

through rethinking the agency’s laboratories from an enterprise 

perspective. That report noted that the EPA’s laboratories have various 

processes for managing and acquiring laboratory equipment, but the 

processes and inventory tools are not connected throughout the agency. 

The report recommended that the EPA link inventory of equipment over 

$500,000 in all laboratories, without regard to mission, to an agencywide 

accessible process. The report also recommended that the EPA explore 

shared use of laboratory equipment in other parts of the agency before 

investment in large capital equipment. The report did not indicate whether 

the EPA agreed with the findings and recommendations.11

 In December 2014, the EPA OIG issued a report12 on the need for better 

management of personal property in EPA warehouses. That report found 

that the EPA did not adequately inventory property nor provide adequate 

oversight to ensure effective and efficient use of EPA resources. The

 

9 U.S. Government Accountability Office report, Environmental Protection Agency: To Better Fulfill Its Mission, 

EPA Needs a More Coordinated Approach to Managing Its Laboratories (GAO-11-347), July 25, 2011.

10 National Academy of Sciences report, Rethinking the Components, Coordination, and Management of the 

U.S. Environmental Protection Agency Laboratories (ISBN 978-0309-31237-0), September 5, 2014.

11 ORD said that, as a rule, the EPA does not respond to specific National Academy report recommendations as it 

does with Government Accountability Office and EPA OIG reports.

12 EPA OIG report, EPA Needs Better Management of Personal Property in Warehouses (Report No. 15-P-0033), 

December 8, 2014.
15-P-0115 6

report recommended, among other things, holding management and staff 

accountable for timely transfer or disposal of excess personal property 

according to agency policy, and updating agencywide policy to prevent 

long-term storage of personal property beyond a year that does not satisfy 

an immediate need. The agency agreed with all recommendations and the 

OIG closed the two recommendations we cited at the time of report 

issuance. Specifically, the agency noted in its Management Audits 

Tracking System that Property Bulletin 14-004 (dated January 8, 2014) 

addresses transaction times and accountability for timely transfer or 

disposal of personal property as well as long-term property storage. The 

EPA further noted that long-term storage should not be determined by 

immediate need but rather by whether an item that will be needed in the 

future is readily available from outside sources, or whether it is more cost 

effective to store the item for future use.

Results of Review

The EPA does not manage its scientific equipment as a business unit or enterprise. 

ORD managers and staff are not aware of federal property management 

requirements in 41 CFR 101 that require regular equipment inspection 

walkthroughs every 2 years and equipment pools to maximize utilization. The 

Federal Property and Administrative Services Act requires regular monitoring to 

timely identify and dispose of obsolete items. ORD has not created a

comprehensive, officewide scientific equipment list that would make ORD’s 

resources visible officewide and agencywide for key research decision-making.

Additionally, ORD does not have clear lines of authority or responsibility over 

equipment accountability and usage. While the National Asset Manager position 

is new to ORD within the past 2 years, the current manager said he received no 

formal training, has had very little coordination with custodial officers, and 

initially focused on buildings more than equipment.

Our review of a sample of research equipment within three laboratories charged 

with risk management and exposure research found that 30 percent (or 30 of 99 

pieces) had not been utilized for 2 to 14 years, as shown in Table 1:

Table 1: Number and dollar value of idle equipment in sample

Number 

sampled

Value of 

sample*

Number

idle

Value of idle 

equipment

Percent idle of 

total sampled

NERL 33 $3,030,639 15 $1,034,117 45.45%

NHEERL 18 3,490,172 2 107,604 11.11%

NRMRL 48 10,218,803 13 1,811,382 27.08%

TOTAL 99 $16,739,614 30 $2,953,103 30.30%

* Value based on acquisition amounts pulled from EPA’s Compass Data Warehouse.

Source: OIG analysis of equipment sampled at three national laboratories.
15-P-0115 7

The laboratories cited various reasons for idle equipment:

 NERL. Of the 15 pieces of idle equipment, seven pieces pertained to a 

rivers and streams research project that ended in June 2012. Additionally, 

two idle pieces were used for large-scale nutrient analyses no longer being 

done. NERL said that remaining idle pieces were either obsolete 

(two pieces), would be used in future water research (two pieces), or 

would be made available ORD-wide (one piece).

 NHEERL. Both pieces of idle equipment had not been used in 3 years. 

The idle pieces—a flow cytometer and an animal transfer station—pertain, 

respectively, to the EPA’s National Ambient Air Quality Standards and 

ORD’s Air, Climate, and Energy research programs. NHEERL justified 

retaining both pieces of idle equipment as backup in case primary pieces 

of research equipment failed.

 NRMRL. For its 13 pieces of idle equipment, NRMRL said:

o One piece with an unknown last usage date is being used for parts.

o Two pieces not utilized since 2012 needed repair. NRMRL used 

the two items for monitoring organic chemical synthesis reactions 

and reducing chemicals formed during drinking water disinfection. 

For one item, NRMRL did not have the funds to purchase a new 

computer and operating system to run the equipment. NRMRL 

plans to purchase these items and utilize the equipment once 

repaired. Similarly, for the other item, the equipment was idle 

while awaiting a replacement computer, software upgrade and 

installation of a new detector. All have since been received and the 

instrument is now back in use.

o Four pieces are obsolete.13 One item, a formaldehyde monitor to 

evaluate emissions in buildings/materials, has not been used since 

2002. Additionally, a laser used to improve data on compounds for 

exposure assessments has not been used since 2001.

o Six pieces have no related active research. These pieces were last 

used from 2009 to 2011 and pertained to—among other areas—

mercury, indoor air, vapor intrusion and particulate matter.

Staff on ORD’s Management Council and its Capital Equipment Committee said 

they were unfamiliar with regulatory requirements. As such, ORD’s National Asset 

Manager said that independent walk-throughs presently occur every 3 to 4 years 

and that, instead of equipment pools, ORD sends informal emails on available 

equipment to agency personal property managers. While ORD’s National Asset 

Manager said divisions annually certify property inventories, we nevertheless 

found idle equipment that laboratories agreed were obsolete and could be excessed.

 

13 These four pieces, together with the two NERL pieces mentioned in the first bullet, means that six of 99 pieces we 

sampled (or 6 percent) were obsolete.
15-P-0115 8

During our review, ORD could not provide us with a comprehensive officewide list 

of all of its scientific equipment. ORD said that it uses the agency’s Compass Data 

Warehouse and a complete inventory can be obtained from this database.

Nevertheless, ORD did not provide us with a complete inventory. ORD’s National 

Asset Manager is developing an ORD-wide list of equipment valued at $75,000 or 

more, but it does not include equipment valued at less than $75,000. Additionally, 

the Office of Administration and Resources Management’s Agency Property 

Management Officer recognized that the current accountable area structure—based 

on geographic locations—is incompatible with the requirements of EPA Policy 

4832. As a result, the Agency Property Management Officer said that each program 

office, such as ORD, will be moving to a single accountable area. ORD said that 

the EPA is soon launching a new property system (Sunflower) which should make 

it easier [than Compass] to navigate and create sub-inventories.

Risks exist by not managing ORD property as a program or an interconnected 

business division. For example, unclear lines of authority could lead to idle

scientific equipment due to confusion over the person(s) responsible to ensure 

usage. Moreover, absent an ORD-wide equipment list, ORD does not know the 

total value of its scientific equipment and, further, could misspend funds by 

purchasing duplicative items. Additionally, ORD research staff—and agency 

program office customers—may not know whether a needed item for air and 

water research is available for use. As such, valuable scientific equipment could 

sit idle when there might be a demand for it elsewhere in ORD or the agency. 

According to ORD, there may be good reasons to retain equipment:

 Keeping older pieces of equipment as backups for newer instrumentation 

can result in potential cost savings due to having a readily available source 

of spare parts for some types of equipment.

 The cost to ship high-priced and sensitive equipment across the country 

can be very expensive and the equipment can be damaged.

 Moving sensitive analytical equipment often voids the manufacturer’s 

warranty and makes it difficult to have a maintenance contract.

 When an analytical instrument is shipped to another lab, that lab must 

have the expertise to operate, repair and maintain the instrument.

 Even though equipment is not currently being utilized, it still contributes 

to the lab’s research capabilities, which allows the lab to quickly adapt to 

changing mission without having to repurchase the equipment.

Conclusion

To minimize risks of having idle equipment and/or misspending funds on 

duplicative equipment, ORD should develop and implement a plan to enhance 

program controls and ensure compliance with federal property regulations. Better 

property management would aid in decision-making on the utilization of current 

equipment as well as the need to purchase new equipment for environmental risk 

management and exposure research.
15-P-0115 9

Recommendations

We recommend that the Assistant Administrator for Research and Development:

1. Develop an ORD equipment list and a system to manage it that will meet

requirements established by the Federal Property and Administrative 

Services Act and by the EPA Office of Administration and Resources 

Management—which has EPA-wide responsibility for developing and 

establishing an effective and efficient agencywide property management 

program—to maintain adequate inventory controls and accountability 

systems for the property. The equipment list should have standard 

fields/nomenclature understood by all laboratories. The information 

compiled should also be relevant to equipment list users.

2. Create an equipment pool that provides relevant and accurate data which 

is updated and maintained per requirements in federal property 

management regulations. 

3. Establish regular equipment utilization walkthroughs and formal reporting 

and follow-up of the results thereof, including updates to equipment lists 

per requirements in federal property management regulations.

4. Conduct independent reviews of the equipment pool procedures to ensure 

their continued effectiveness per requirements in federal property 

management regulations.

5. Define the role, responsibility and authority of the National Asset 

Manager within the framework of the EPA’s personal property policies 

and procedures.

6. Excess obsolete equipment identified during OIG site visits.

Agency Comments and OIG Evaluation

In its response to our official draft report, ORD did not agree with the wording of 

Recommendation 1 and suggested some specific additional wording to reflect the 

property management responsibility that ORD shares with the EPA’s Office of 

Administration and Resources Management. We agreed and made the proposed 

changes. ORD subsequently agreed with Recommendation 1, which is resolved 

and open with agreed-to actions due for completion in October 2015.

ORD agreed with Recommendations 2 through 6, and each is resolved and open 

with agreed-to actions due for completion in June 2015.

Appendix A includes ORD’s full response to the official draft report and the 

OIG’s comments.
15-P-0115 10

Status of Recommendations and 

Potential Monetary Benefits

RECOMMENDATIONS

POTENTIAL MONETARY 

BENEFITS (in $000s)

Rec. No.

Page 

No. Subject Status1 Action Official

Planned 

Completion 

Date

Claimed 

Amount

Agreed-To 

Amount

1 9 Develop an ORD equipment list and a system to 

manage it that will meet requirements established by 

the Federal Property and Administrative Services Act 

and by the EPA Office of Administration and 

Resources Management—which has EPA-wide 

responsibility for developing and establishing an 

effective and efficient agencywide property 

management program—to maintain adequate 

inventory controls and accountability systems for the 

property. The equipment list should have standard 

fields/nomenclature understood by all laboratories. 

The information compiled should also be relevant to 

equipment list users.

O Assistant Administrator for 

Research and Development

10/1/15

2 9 Create an equipment pool that provides relevant and 

accurate data which is updated and maintained per 

requirements in federal property management 

regulations.

O Assistant Administrator for 

Research and Development

6/1/15

3 9 Establish regular equipment utilization walkthroughs 

and formal reporting and follow-up of the results 

thereof, including updates to equipment lists per 

requirements in federal property management 

regulations.

O Assistant Administrator for 

Research and Development

6/1/15

4 9 Conduct independent reviews of the equipment pool 

procedures to ensure their continued effectiveness 

per requirements in federal property management 

regulations.

O Assistant Administrator for 

Research and Development

6/1/15

5 9 Define the role, responsibility and authority of the 

National Asset Manager within the framework of the 

EPA’s personal property policies and procedures.

O Assistant Administrator for 

Research and Development

6/1/15

6 9 Excess obsolete equipment identified during OIG

site visits.

O Assistant Administrator for 

Research and Development

6/1/15

1 O = Recommendation is open with agreed-to corrective actions pending. 

C = Recommendation is closed with all agreed-to actions completed. 

U = Recommendation is unresolved with resolution efforts in progress.
15-P-0115 11

Appendix A

Agency Response to Official Draft Report

and OIG Comments

February 11, 2015

MEMORANDUM

SUBJECT: Response to the Office of Inspector General (OIG) Draft Report, To Ensure 

Greater Use of Scientific Equipment, the Office of Research and Development 

Should Use an Enterprise Approach to Property Management, Project Number 

OPE-FY14-0024

FROM: Lek Kadeli, Acting Assistant Administrator /s/

TO: Arthur A. Elkins, Jr., Inspector General

Office of Inspector General

Thank you for the opportunity to respond to the OIG draft report titled To Ensure Greater Use of 

Scientific Equipment, the Office of Research and Development Should Use an Enterprise 

Approach to Property Management. As you know, sound science is a foundation of EPA’s work 

and its mission to protect human health and the environment. One way we ensure sound 

laboratory analysis and scientific results in ORD is by safeguarding, maintaining, and properly 

calibrating our laboratory instruments and equipment. ORD agrees with and appreciates the 

OIG’s acknowledgement that ORD had no significant, reportable issues related to safeguarding, 

maintaining or calibrating laboratory research instruments and equipment. 

ORD is in full agreement with recommendations 2 – 6 described in the OIG draft report. ORD 

corrective actions for OIG recommendations 2 – 6 are outlined in Table 1 on page 3 of this 

memorandum. 

ORD does not agree with the wording of recommendation 1 in the draft OIG report because it 

does not include sufficient context for evaluation and accountability. The current wording of the 

OIG recommendation 1 is

“Develop an ORD equipment list and a system to manage it, per requirements in the 

Federal Property and Administrative Services Act, to maintain adequate inventory 

controls and accountability systems for the property. The equipment list should have 

standard fields/nomenclature understood by all laboratories. The information compiled 

should also be relevant to equipment list users.” 
15-P-0115 12

OIG Comment #1: We concur with ORD’s suggested edits to our first recommendation and 

revised our report accordingly.

After a detailed review of the draft OIG report, ORD believes that the wording in 

recommendation 1 should be expanded to include the following essential context:

“Develop an ORD equipment list and a system to manage it that will meet requirements 

established by the Federal Property and Administrative Services Act and by the EPA 

Office of Administration and Resources Management (OARM)—which has EPA-wide 

responsibility for developing and establishing an effective and efficient agency-wide 

property management program—to maintain adequate inventory controls and 

accountability systems for the property. The equipment list should have standard 

fields/nomenclature understood by all laboratories. The information compiled should also 

be relevant to equipment list users.”

One reason to change the wording in recommendation 1 is that the draft OIG report 

acknowledges (on page 3) that EPA’s Office of Administration and Resources Management 

(OARM) has agency-wide responsibility for developing and establishing an effective and 

efficient Agency-wide property management program—and that the 4832 EPA Personal 

Property Policy and Procedures manual is the Agency’s primary and authoritative reference for 

property management. A second reason to change the wording in recommendation 1 is that the 

draft OIG report does not include one important fact: that ORD works with OARM and with the 

systems it establishes for effective and efficient property management. A third reason to change 

the wording in recommendation 1 is that the ORD revision more accurately describes the context 

for evaluation and accountability.

The ORD corrective actions for this recommendation—based on the recommended change in 

wording to recommendation 1—are outlined in Table 2 on page 4 of this memorandum. 

In summary, to address the OIG’s overall findings and recommendations, ORD will take actions 

described in Tables 1 and 2 to improve its protocols for documenting and managing utilization of 

laboratory equipment, for identifying potential laboratory equipment for pooling, and for 

removing obsolete laboratory equipment during walk-throughs. ORD is looking forward to 

strengthening its systematic approach in these areas to ensure improved use of its laboratory 

instruments and equipment. 

Should you or your staff have any questions, please contact Pai-Yei Whung, Director of 

ORD/OARS, at 919-541-7963. 

cc: Tom Burke

 Bob Kavlock

 Pai-Yei Whung

 Amy Battaglia

 ORD Laboratory Directors
15-P-0115 13

OIG Comment #2: We believe ORD’s planned corrective actions address our 

recommendations. We will monitor the EPA’s Management Audit Tracking System for more 

specificity on ORD’s completed actions to address our recommendations. These 

recommendations are resolved and open with agreed-to actions pending.

Table 1.

ORD Corrective Actions based on ORD Agreement with Proposed OIG Recommendations 

#2-6

No. OIG Recommendation Responsible 

Office ORD Corrective Action

Estimated 

Completion 

Date

2

Create an equipment pool that 

provides relevant and accurate 

data which is updated and 

maintained per requirements in 

federal property management 

regulations.

ORD/ OARS

National Asset 

Manager

ORD will create an equipment pool 

of available equipment. The 

equipment pool will be maintained 

by the National Asset Manager. 

6/1/2015

3

Establish regular equipment 

utilization walkthroughs and 

formal reporting and follow up 

of the results thereof, including 

updates to equipment lists per 

requirements in federal 

property management 

regulations.

ORD/OARS 

National Asset 

Manager, 

Division 

Managers and 

Division Property 

Specialist

The National Asset Manager will 

ensure each site is aware of the 

biannual requirement to perform 

equipment utilization 

walkthroughs. This requirement is 

different than an annual property 

inventory. A list of underutilized 

equipment will be maintained at 

each site. Obsolete equipment will 

be excessed. 

6/1/2015

4

Conduct independent reviews 

of the equipment pool 

procedures to ensure their 

continued effectiveness per 

requirements in federal 

property management 

regulations.

ORD/OARS 

National Asset 

Manager and 

Property 

Specialist

The National Asset Manager and a 

selection of property specialists will 

review the equipment pool 

procedures for ORD. 

Findings/Recommendations will be 

forwarded to ORD Management for 

review/implementation.

6/1/2015

5

Define the role, responsibility 

and authority of the National 

Asset Manager within the 

framework of the EPA’s 

personal property policies and 

procedures.

ORD/OARS 

Management

Specific roles, responsibilities, and 

authority will be reflected in the 

National Asset Manager Position 

Description.

6/1/2015

6

Excess obsolete equipment 

identified during our site visits.

ORD/OARS 

National Asset 

Manager, 

Division 

Managers and 

Division Property 

Specialist

The National Asset Manager will 

work with the property specialist to 

ensure this is accomplished. Prior 

to excessing obsolete equipment, 

items will be placed in the pool of 

available equipment (see Finding 2) 

if deemed necessary.

6/1/2015
15-P-0115 14

OIG Comment #3: We concur with ORD’s edits to our first recommendation and we revised our 

report accordingly. We believe ORD’s planned actions address our recommendation. We will 

monitor the EPA’s Management Audit Tracking System for more specificity on ORD’s completed 

actions to address our recommendation. This recommendation is resolved and open with agreed-to 

actions pending.

Table 2.

ORD Corrective Actions based on the ORD Change to Proposed OIG Recommendation # 1 

No. OIG 

Recommendation

ORD Proposed Change to 

OIG Recommendation

Responsible 

Office ORD Corrective Actions

Estimated 

Completio

n Date

1

Develop an ORD 

equipment list and a 

system to manage it, 

per requirements in 

the Federal Property 

and Administrative 

Services Act, to 

maintain adequate 

inventory controls 

and accountability 

systems for the 

property. The 

equipment list should 

have standard 

fields/nomenclature 

understood by all 

laboratories. The 

information compiled 

should also be 

relevant to 

equipment list users.

Develop an ORD equipment 

list and a system to manage 

it that will meet 

requirements established by 

the Federal Property and 

Administrative Services Act 

and by the EPA Office of 

Administration and 

Research Management 

(OARM)—which has EPAwide responsibility for 

developing and establishing 

an effective and efficient 

agency-wide property 

management program—to 

maintain adequate inventory 

controls and accountability 

systems for the property. 

The equipment list should 

have standard 

fields/nomenclature 

understood by all 

laboratories. The 

information compiled 

should also be relevant to 

equipment list users.

ORD/OARS 

National 

Asset 

Manager

1. As ORD develops its 

equipment list and 

management system, ORD 

initially will use the existing 

inventory database used by 

EPA and OARM—the 

Compass Data Warehouse 

(CDW). Although 

cumbersome, the CDW has 

standard fields and a 

complete ORD inventory 

can be obtained with this 

database. 

2. When EPA and OARM 

launch the agency’s new 

property management 

system (Sunflower) later in 

FY15, ORD will transition 

its inventory data base to 

this system.

3. The ORD National Asset 

Manager also will work 

with OARM to determine if 

changes are required to the 

EPA Personal Property 

Manual to comply with 

requirements in the Federal 

Property and Administrative 

Services Act.

10/1/15
15-P-0115 15

Appendix B

Distribution

Office of the Administrator

Assistant Administrator for Research and Development

Agency Follow-Up Official (the CFO)

Agency Follow-Up Coordinator

General Counsel

Associate Administrator for Congressional and Intergovernmental Relations

Associate Administrator for Public Affairs

Deputy Assistant Administrator for Science, Office of Research and Development

Deputy Assistant Administrator and Science Advisor, Office of Research and Development

Director, National Exposure Research Laboratory, Office of Research and Development

Director, National Health and Environmental Effects Research Laboratory, Office of Research 

 and Development

Director, National Risk Management Research Laboratory, Office of Research and Development

Audit Follow-Up Coordinator, Office of Research and Development