ENVIRONMENTAL 

PROTECTION AGENCY

Actions Needed to Improve 

Planning, Coordination, and 

Leadership of EPA 

Laboratories 

Statement of David C. Trimble

Natural Resources and Environment

Testimony 

Before the Subcommittee on Energy and 

the Environment, Committee on Science, 

Space, and Technology, House of 

Representatives

For Release on Delivery 

Expected at 2:00 p.m. EST

Thursday, November 17, 2011

GAO-12-236T

United States Government Accountability Office

GAO
 

Page 1 GAO-12-236T 

Chairman Harris, Ranking Member Miller, and Members of the 

Subcommittee:

I am pleased to be here today to discuss the research and development 

activities of the Environmental Protection Agency (EPA) and the findings 

of our recent report on the agency’s laboratory enterprise.1 EPA was 

established in 1970 to consolidate a variety of federal research, 

monitoring, standard-setting, and enforcement activities into one agency 

for ensuring the joint protection of environmental quality and human 

health.2 Scientific research, knowledge, and technical information are 

fundamental to EPA’s mission and inform its standard-setting, regulatory, 

compliance, and enforcement functions. The agency’s scientific 

performance is particularly important as complex environmental issues 

emerge and evolve, and controversy continues to surround many of the 

agency’s areas of responsibility. Unlike other primarily science-focused 

federal agencies, such as the National Institutes of Health or the National 

Science Foundation, EPA’s scientific research, technical support, and 

analytical services underpin the policies and regulations the agency 

implements. Therefore, the agency operates its own laboratory 

enterprise. This enterprise is made up of 37 laboratories that are housed 

in about 170 buildings and facilities located in 30 cities across the nation. 

Specifically, EPA’s Office of Research and Development (ORD) operates 

18 laboratories with primary responsibility for research and development. 

Four of EPA’s five national program offices3

 

1

GAO, Environmental Protection Agency: To Better Fulfill Its Mission, EPA Needs a More 

Coordinated Approach to Managing Its Laboratories, 

operate nine laboratories 

with primary responsibility for supporting regulatory implementation, 

compliance, enforcement, and emergency response. Each of EPA’s 10 

regional offices operates a laboratory with responsibilities for a variety of 

applied sciences; analytical services; technical support to federal, state, 

and local laboratories; monitoring; compliance and enforcement; and 

emergency response.

GAO-11-347 (Washington, D.C.: July 

25, 2011).

2

Reorganization Plan No. 3 of 1970, 35 Fed. Reg. 15623 (Dec. 2, 1970) (5 U.S.C. 

Appendix 1). 

3

The national program offices with laboratories are the Office of Air and Radiation, the 

Office of Enforcement and Compliance Assurance, the Office of Chemical Safety and 

Pollution Prevention, and the Office of Solid Waste and Emergency Response.

 
 

Page 2 GAO-12-236T 

Over the past 20 years, independent evaluations by the National Research 

Council and others have addressed planning, coordination, or leadership 

issues associated with EPA’s science activities.4 The scope of these 

evaluations varied, but collectively they recognized the need for EPA to 

improve long-term planning, priority setting, and coordination of laboratory 

activities; establish leadership for agencywide scientific oversight and 

decision making; and better manage the laboratories’ workforce and 

infrastructure. When it was established in 1970, EPA inherited 42 

laboratories from programs in various federal departments. According to 

EPA’s historian, EPA closed or consolidated some laboratories it inherited 

and created additional laboratories to support its mission. Nevertheless, 

EPA’s historian reported that the location of most of EPA’s present 

laboratories is largely the same as the location of its original laboratories in 

part because of political objections to closing facilities and conflicting 

organizational philosophies, such as operating centralized laboratories for 

efficiency versus operating decentralized laboratories for flexibility and 

responsiveness. Other federal agencies face similar challenges with 

excess and underused property. Because of these challenges, GAO has 

designated federal real property as an area of high risk.5

This statement summarizes the findings of our report issued in July of this 

year that examines the extent to which EPA (1) has addressed the 

findings of independent evaluations performed by the National Research 

Council and others regarding long-term planning, coordination, and 

leadership issues; (2) uses an agencywide, coordinated approach for 

managing its laboratory physical infrastructure; and (3) uses a 

comprehensive planning process to manage its laboratory workforce. In 

preparing this testimony, we relied on the work supporting our July report. 

In conducting that work, we reviewed agency documents and 

independent evaluations, visited EPA laboratories, interviewed agency 

officials, and examined agency databases; our recent report contains a 

detailed description of our scope and methodology. All of the work for our 

July report was performed in accordance with generally accepted 

government auditing standards.

 

4

The National Research Council is the principal operating agency of both the National 

Academy of Sciences and the National Academy of Engineering. 

5

High-Risk Series: An Update, GAO-11-278 (Washington, D.C.: February 2011).
 

Page 3 GAO-12-236T 

EPA has taken some actions but has not fully addressed the findings and 

recommendations of five independent evaluations over the past 20 years 

regarding long-standing planning, coordination, and leadership issues 

that hamper the quality, effectiveness, and efficiency of its science 

activities, including its laboratory operations.

First, EPA has yet to fully address planning and coordination issues 

identified by a 1992 independent, expert panel evaluation that 

recommended that EPA develop and implement an overarching issuebased planning process that integrates and coordinates scientific efforts 

throughout the agency, including the important work of its 37 

laboratories.6

Second, EPA has also not fully addressed recommendations from a 1994 

independent evaluation by the MITRE Corporation to consolidate and 

realign its laboratory facilities and workforce

That evaluation found that EPA’s science was of uneven 

quality and that the agency lacked a coherent science agenda and 

operational plan to guide scientific efforts throughout the agency. 

Because EPA did not implement the evaluation’s recommendation, EPA’s 

programs, regional officials, and ORD continue to independently plan and 

coordinate the activities of their respective laboratories based on their 

own offices’ priorities and needs.

7

—even though this 

evaluation found that the geographic separation of laboratories hampered 

their efficiency and technical operations and that consolidation and 

realignment could improve planning and coordination issues that have 

hampered its science and technical community for decades. In its 

evaluation, MITRE recommended that EPA (1) realign and consolidate 

the ORD laboratories; (2) consolidate program laboratories in the Office 

of Prevention, Pesticides, and Toxic Substances8

 

6

Environmental Protection Agency, Safeguarding the Future: Credible Science, Credible 

Decisions, The Report of the Expert Panel on the Role of Science at EPA, EPA/600/9-

91/050 (Washington, D.C.: March 1992). 

and the two 

laboratories under the Office of Radiation and Indoor Air; and (3) through 

consolidation, reduce the number of regional office laboratories to a few 

laboratories with a national service focus. In response to the MITRE 

7

MITRE Corporation, Center for Environment, Resources, and Space, Assessment of the 

Scientific and Technical Laboratories and Facilities of the U.S. Environmental Protection 

Agency (McLean, Va., May 1994). 

8

Now known as the Office of Chemical Safety and Pollution Prevention. 

EPA Has Not Fully 

Addressed Findings of 

Evaluations on Longstanding Planning, 

Coordination, or 

Leadership Issues
 

Page 4 GAO-12-236T 

study, an agencywide steering committee formed by EPA to consider 

restructuring and consolidation options issued a report to the 

Administrator in July 1994.9

Third, EPA has not fully addressed recommendations from the 

independent evaluations regarding leadership of its research and 

laboratory operations.

The steering committee report stated that 

combining ORD laboratories at a single location could improve teamwork 

and raise productivity but concluded that, for the near term, ORD should 

be functionally reorganized but not physically consolidated. Regarding 

program office laboratory consolidations, the Office of Radiation and 

Indoor Air did not physically consolidate its laboratories but did 

administratively and physically consolidate its Las Vegas laboratory with 

ORD’s Las Vegas radiation laboratory, and the Office of Prevention, 

Pesticides, and Toxic Substances colocated three of four laboratories 

with the region 3 laboratory. As for the regional laboratories, the steering 

committee’s report endorsed the current decentralized regional model but 

did not provide a justification for its position.

10

 

9

Environmental Protection Agency, Research, Development, and Technical Services at 

EPA: A New Beginning, Report to the Administrator, EPA/600/R-94/122 (Washington, 

D.C.: July 1994). 

More specifically, EPA has not appointed a top 

science official with responsibility and authority for all the research, 

science, and technical functions of the agency— even though one study 

found that the lack of a top science official was a formula for weak 

scientific performance in the agency and poor scientific credibility outside 

the agency. Instead, EPA’s efforts to establish leadership over its 

laboratory enterprise have relied on advisory positions and councils to 

achieve consensus and voluntary cooperation of ORD and the agency’s 

program and regional offices. Because of the limited success of EPA’s 

advisory positions and councils and in the absence of a central science 

policy authority, the National Research Council in 2000 recommended 

that EPA request authority from Congress to create a new position of 

deputy administrator for science and technology, with managerial 

authority to coordinate and oversee all the agency’s scientific and 

10National Research Council, Interim Report of the Committee on Research and Peer 

Review in EPA (Washington, D.C., National Academies Press, 1995); Environmental 

Protection Agency, Office of Inspector General, Regional Laboratories (Washington, D.C., 

Aug. 20, 1997); and National Research Council, Strengthening Science at the U.S. 

Environmental Protection Agency: Research-Management and Peer Review Practices 

(Washington, D.C., National Academies Press, 2000). 
 

Page 5 GAO-12-236T 

technical activities. To date, EPA has not requested authority to create a 

new position of deputy administrator for science and technology and 

continues to operate its laboratories under the direction of 15 different 

senior officials using 15 different organizational and management 

structures. As a result, EPA has a limited ability to know if scientific 

activities are being unintentionally duplicated among the laboratories or if 

opportunities exist to collaborate and share scientific expertise, 

equipment, and facilities across EPA’s organizational boundaries.

On the basis of our analysis of EPA’s facility master planning process, we 

found that EPA manages its laboratory facilities on a site-by-site basis 

and does not evaluate each site in the context of all the agency’s real 

property holdings—as recommended by the National Research Council 

report in 2004.11 EPA’s facility master plans are intended to be the basis 

for justifying its building and facilities spending, which was $29.9 million in 

fiscal year 2010, and allocating those funds to specific repair and 

improvement projects. Master plans should contain, among other things, 

information on mission capabilities, use of space, and condition of 

individual laboratory sites. In addition, we found that most facility master 

plans were out of date. EPA’s real property asset management plan 

states that facility master plans are supposed to be updated every 5 years 

to reflect changes in facility condition and mission, but we found that 11 of 

20 master plans were out of date and 2 of 20 had not been created yet.12

Because EPA makes capital improvement decisions on a site-by-site 

basis using master plans that are often outdated, it cannot be assured it is 

allocating its funds most appropriately. According to officials responsible 

for allocating capital improvement resources, they try to spread these 

funds across the agency’s offices and regions equitably but capital 

improvement funds have not kept pace with requests. The pressure and 

need to effectively share and allocate limited resources among EPA’s 

many laboratories were also noted in a 1994 National Academy of Public 

Administration report on EPA’s laboratory infrastructure, which found that 

 

11National Research Council, Investments in Federal Facilities: Asset Management 

Strategies for the 21st Century (Washington, D.C., National Academies Press, 2004). 

12Master plans are created for owned properties only. We found there were no master 

plans for two laboratory properties located in Research Triangle Park, N.C., and Fort 

Meade, Md. We also found that 9 of the 11 outdated master plans were over 10 years old. 

EPA Has Not Taken 

an Agencywide, 

Coordinated 

Approach to Manage 

Its Laboratory 

Physical 

Infrastructure
 

Page 6 GAO-12-236T 

EPA has “too many labs in too many locations often without sufficient 

resources to sustain a coherent stable program.”13

In addition, because decisions regarding laboratory facilities are made 

independently of one another, opportunities to improve operating 

efficiencies can be lost. Specifically, we found cases where laboratories 

that were previously colocated moved into separate space without 

considering the potential benefits of remaining colocated. In one case, we 

found that the relocation increased some operating costs because the 

laboratories then had two facility managers and two security contracts 

and associated personnel because of different requirements for the 

leased facility. In another case, when two laboratories that were 

previously colocated moved into separate new leased laboratories 

several miles apart, agency officials said that they did not know to what 

extent this move may have resulted in increased operating cost.

EPA also does not have sufficiently complete and reliable data to make 

informed decisions for managing its facilities. Since 2003, when GAO first 

designated federal real property management as an area of high risk, 

agencies have come under increasing pressure to manage their real 

property assets more effectively.14 In February 2004, the President issued 

an executive order directing agencies to, among other things, improve the 

operational and financial management of their real property inventory.15

The order established a Federal Real Property Council within the Office of 

Management and Budget (OMB), which has developed guiding principles 

for real property asset management. In response to a June 2010 

presidential memorandum directing agencies to accelerate efforts to 

identify and eliminate excess properties,16

 

13National Academy of Public Administration, A Review, Evaluation, and Critique of a 

Study of EPA Laboratories by the MITRE Corporation and Additional Commentary on EPA 

Science and Technology Programs (Washington, D.C., May 1994), 10. 

in July 2010 EPA reported to 

the OMB that it does not anticipate the disposal of any of its owned 

laboratories and major assets in the near future because these assets are 

14High-Risk Series: An Update, GAO-011-278 (Washington, D.C.: February 2011).

15Federal Real Property Asset Management, Exec. Order No. 13327, 69 Fed. Reg. 5897 

(Feb. 4, 2004). 

16Presidential Memorandum, Disposing of Unneeded Federal Real Estate, 75 Fed. Reg. 

33987 (June 16, 2010). 
 

Page 7 GAO-12-236T 

fully used and considered critical for EPA’s mission.17

• First, EPA does not maintain accurate data to determine if there is an 

agency need for laboratory facilities because many facility master 

plans are often out of date. According to EPA’s asset management 

plan, the master plans are tools that communicate the link between 

mission priorities and facilities. However, without up-to-date master 

plans, EPA does not have accurate data to determine if laboratory 

facilities are needed for its mission.

EPA stated that 

decisions regarding facility disposal are made using the Federal Real 

Property Council’s guidance but we found that EPA does not have the 

information needed to effectively implement this guidance. Specifically, 

EPA does not have accurate, reliable information regarding (1) the need 

for facilities, (2) property usage, (3) facility condition, and (4) facility 

operating efficiency—thereby undermining the credibility of any decisions 

based on this approach.

• Second, the agency does not have accurate data on space needs and 

usage because many facility master plans containing space utilization 

analyses are out of date. EPA also does not use public and 

commercial space usage benchmarks—as recommended by the 

Federal Real Property Council—to calculate usage rates for its 

laboratories. Instead, EPA measures laboratory usage on the basis of 

interviews with local laboratory officials. According to EPA officials, 

they do not use benchmarks because the work of the laboratories 

varies. In 2008, however, an EPA contractor created a laboratory 

benchmark based on those used by comparable facilities at the 

Centers for Disease Control and Prevention, the National Institutes of 

Health, the Department of Energy, and several research universities 

to evaluate space at two ORD laboratories in North Carolina. 

Consequently, we believe that objective benchmarks can be 

developed for EPA’s unique laboratory requirements. In addition, the 

contractor’s analysis concluded that EPA could save $1.68 million in 

annual leasing and $800,000 in annual energy costs through 

consolidation of the two ORD laboratories. Agency officials told us 

they hope to consolidate the laboratories in fiscal year 2012 if funds 

are available.

 

17Environmental Protection Agency, Real Property Cost Savings and Innovation Plan 

(Washington, D.C., July 23, 2010. 
 

Page 8 GAO-12-236T 

• Third, the agency does not have accurate data for assessing facilities’ 

condition because condition assessments contained in facility master 

plans are often outdated. The data may also be unreliable because 

data entered by local facility managers are not verified, according to 

agency officials. Such verification could involve edit checks or controls 

to help ensure the data are entered accurately.

• Fourth, EPA does not have reliable operating cost data for its 

laboratory enterprise, because the agency’s financial management 

system does not track operating costs in sufficient detail to break out 

information for individual laboratories or for the laboratory enterprise 

as a whole. Reliable operating cost data are important in determining 

whether a laboratory facility is operating efficiently, a determination 

that should inform both capital investment and property disposal 

decisions.

EPA does not use a comprehensive planning process for managing its 

laboratories’ workforce. For example, we found that not all of the regional 

and program offices with laboratories prepared workforce plans as part of 

an agencywide planning effort in 2007, and for those that did, most did 

not specifically address their laboratories’ workforce. In fact, some 

regional management and human resource officials we spoke with were 

unaware of the requirement to submit workforce plans to the Office of 

Human Resources. Some of these managers told us the program and 

regional workforce plans were a paperwork exercise, irrelevant to the way 

the workforce is actually managed. Managers in program and regional 

offices said that workforce planning for their respective laboratories is 

fundamentally driven by the annual budgets of program and regional 

offices and ceilings for full-time equivalents (FTE).18

In addition, none of the program and regional workforce plans we 

reviewed described any effort to work across organizational boundaries to 

integrate or coordinate their workforce with the workforces of other EPA 

laboratories. For example, although two regional workforce plans 

discussed potential vulnerability if highly skilled laboratory personnel 

retired, neither plan explored options for sharing resources across 

 

18An FTE consists of one or more employed individuals who collectively complete 2,080 

work hours in a given year. Therefore, one full-time employee or two half-time employees 

equal one FTE. 

EPA Does Not Use a 

Comprehensive 

Workforce Planning 

Process for Its 

Laboratories
 

Page 9 GAO-12-236T 

regional boundaries to address potential skill gaps. According to EPA’s 

Regional Laboratory System 2009 Annual Report, many of the regional 

laboratories provide the same or similar core analytical capabilities—

including a full range of routine and specialized chemical and biological 

testing of air, water, soil, sediment, tissue, and hazardous waste. 

Nonetheless, in these workforce plans, each region independently 

determines and attempts to address its individual workforce needs. As a 

result, by not exploring options for sharing resources among the ORD, 

program, and regional boundaries to address potential skill gaps, EPA 

may be missing opportunities to fill critical occupation needs through 

resource sharing.

Moreover, EPA does not have basic demographic information on the 

number of federal and contract employees currently working in its 37 

laboratories. Specifically, EPA does not routinely compile the information 

needed to know how many scientific and technical employees it has 

working in its laboratories, where they are located, what functions they 

perform, or what specialized skills they may have. In addition, the agency 

does not have a workload analysis for the laboratories to help determine 

the optimal numbers and distribution of staff throughout the enterprise. 

We believe that such information is essential for EPA to prepare a 

comprehensive laboratory workforce plan to achieve the agency’s mission 

with limited resources. Because EPA’s laboratory workforce is managed 

separately by 15 independent senior officials, information about that 

workforce is tracked separately and is not readily available or routinely 

compiled or evaluated. Instead, EPA has relied on ad hoc calls for 

information to compile such data.

In response to our prior reports on EPA’s workforce strategy19

 

19GAO, Human Capital: Implementing an Effective Workforce Strategy Would Help EPA to 

Achieve Its Strategic Goals, 

and the 

work of the EPA Inspector General, EPA hired a contractor in 2009, in 

part to conduct a study to provide information about the agency’s overall 

workload, including staffing levels and workload shifts for six major 

GAO-01-812 (Washington, D.C.: July 31, 2001); Human 

Capital: Key Principles for Effective Strategic Workforce Planning, GAO-04-39

(Washington, D.C.: Dec. 11, 2003); Clean Water Act: Improved Resource Planning Would 

Help EPA Better Respond to Changing Needs and Fiscal Constraints, GAO-05-721

(Washington, D.C.: July 22, 2005); EPA’s Execution of Its Fiscal Year 2007 New Budget 

Authority for the Enforcement and Compliance Assurance Program in the Regional 

Offices, GAO-08-1109R (Washington, D.C.: Sept. 26, 2008); Environmental Protection 

Agency: Major Management Challenges, GAO-09-434 (Washington, D.C.: Mar. 4, 2009). 
 

Page 10 GAO-12-236T 

functions, including scientific research. In its budget justification for fiscal 

year 2012, however, the agency reported to Congress that a survey of the 

existing workload information provided by the contractor will not 

immediately provide information sufficient to determine whether changes 

are needed in workforce levels. As of October 2011, EPA had not 

released the results of this study, and we therefore cannot comment on 

whether its content has implications for the laboratories. The agency 

asked its National Advisory Council for Environmental Policy and 

Technology to help address scientific and technical competencies as it 

develops a new agencywide workforce plan. However, the new plan is not 

complete, and therefore it is too early to tell whether the council’s 

recommendations will have implications for the laboratories.

Finally, in our July 2011 report on EPA’s laboratory enterprise we 

recommended, among other things, that EPA develop a coordinated 

planning process for its scientific activities and appoint a top-level official 

with authority over all the laboratories, improve physical and real property 

planning decisions, and develop a workforce planning process for all 

laboratories that reflects current and future needs of laboratory facilities. 

In written comments on the report, EPA generally agreed with our findings 

and recommendations.

Chairman Harris, Ranking Member Miller, this concludes my prepared 

statement. I would be happy to respond to any questions that you or other 

members of the subcommittee may have at this time.

For further information on this statement, please contact David Trimble at 

(202) 512-3841 or trimbled@gao.gov. Contact points for our 

Congressional Relations and Public Affairs offices may be found on the 

last page of this statement. Other staff that made key contributions to this 

testimony include Diane LoFaro, Assistant Director; Jamie Meuwissen; 

Angela Miles; and Dan Semick.

GAO Contact and 

Staff 

Acknowledgments

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