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EPA OIG’s Compliance 

With EPA Passport Guidance 

Report No. 14-B-0244 May 1, 2014

U.S. ENVIRONMENTAL PROTECTION AGENCY

OFFICE OF INSPECTOR GENERAL
Report Contributors: Jean Bloom

Kevin Collins

 

Abbreviations

CFR Code of Federal Regulations 

EPA U.S. Environmental Protection Agency

OIG Office of Inspector General

OITA Office of International and Tribal Affairs

PII Personally identifiable information

Hotline Suggestions for Audits or Evaluations

To report fraud, waste or abuse, contact us 

through one of the following methods:

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contact us through one of the following methods:

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online:

write:

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1-888-546-8740

1-202-566-2599

http://www.epa.gov/oig/hotline.htm

EPA Inspector General Hotline 

1200 Pennsylvania Avenue, NW

Mailcode 2431T

Washington, DC 20460

email:

phone:

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write:

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http://www.epa.gov/oig/contact.html#Full_Info

EPA Inspector General 

1200 Pennsylvania Avenue, NW

Mailcode 2410T

Washington, DC 20460
 

 14-B-0244

May 1, 2014

Why We Did This Review

On August 27, 2013, a member 

of the U.S. Senate Committee 

on Environment and Public 

Works requested that the 

U.S. Environmental Protection 

Agency (EPA), Office of 

Inspector General (OIG), 

initiate work in connection with 

a fraud committed by John C. 

Beale, a former Senior Policy 

Advisor with the EPA’s Office of 

Air and Radiation. One of the 

areas audited was the agency’s 

vetting process for new 

employees. We also audited 

the process for official 

passports. The audit disclosed

issues that impact the OIG and 

require immediate attention.

This report addresses the 

following EPA theme:

 Embracing EPA as a high 

performing organization.

For further information, 

contact our public affairs office 

at (202) 566-2391.

The full report is at:

www.epa.gov/oig/reports/2014/ 

20140501-14-B-0244.pdf

EPA OIG’s Compliance With EPA Passport Guidance

 What We Found

The EPA OIG is not in compliance with EPA guidance 

governing the control and security of official passports 

issued to OIG employees. The total number of OIG 

employees with an official passport is unknown. 

The OIG does not have any policies and procedures 

associated with official passports (i.e., the issuance, control and security of 

official passports). The conditions occurred due to a lack of knowledge within the 

OIG concerning official passport requirements, and a lack of guidance and 

oversight from the OIG and the EPA’s Office of International and Tribal Affairs 

(OITA). The lack of compliance with OITA guidance may put the OIG in the 

position where sensitive personally identifiable information (PII) is not being 

adequately protected. The lack of control could also result in the release of 

sensitive PII due to missing, misused or improperly destroyed official passports.

 Recommendations 

We recommend that the OIG identify all official passports issued to OIG 

employees and request that all official passports be returned to the OITA for 

proper storage or cancellation. We also recommend that the OIG provide the 

OITA with the names and available passport numbers of OIG employees whose 

passports have not been located, and request that the OITA notify the 

U.S. Department of State. In addition, we recommend that the OIG develop and 

implement one OIG-wide policy and procedure for the issuance and control of 

official passports and designate an international travel coordinator position. 

U.S. Environmental Protection Agency

Office of Inspector General

At a Glance

The EPA OIG needs 

to ensure that it 

complies with EPA 

passport guidance to 

protect sensitive PII.
May 1, 2014

MEMORANDUM

SUBJECT: EPA OIG’s Compliance With EPA Passport Guidance

Report No. 14-B-0244

FROM: Kevin Christensen, Acting Assistant Inspector General 

Office of Audit

TO: Charles Sheehan, Deputy Inspector General

As part of our continuing work on internal controls as a result of the John Beale investigation, we 

initiated an audit of the U.S. Environmental Protection Agency’s internal controls over passport security. 

We identified issues that impact the Office of Inspector General (OIG) and require immediate attention. 

Action Required

Please provide a written response to this report within 60 calendar days. You should include planned 

corrective actions and completion dates for the recommendations. Your response will be posted on the 

OIG’s public website, along with our memorandum commenting on your response. Your response 

should be provided as an Adobe PDF file that complies with the accessibility requirements of Section 

508 of the Rehabilitation Act of 1973, as amended. If your response contains data that you do not want 

released to the public, you should identify the data for redaction or removal, along with corresponding 

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

If you have any questions, please contact me at (202) 566-1007 or christensen.kevin@epa.gov; or 

Robert Adachi, Director of Forensic Audits, at (415) 947-4537 or adachi.robert@epa.gov.

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C. 20460

OFFICE OF

INSPECTOR GENERAL
U.S. Environmental Protection Agency

Office of Inspector General

EPA OIG’s Compliance

With EPA Passport Guidance 

Report No. 14-B-0244 

May 1, 2014
2

Reasons for Review

 Part of continuing work on internal controls in response 

to a member of the U.S. Senate Committee on 

Environmental and Public Works request for work in 

connection with a fraud committed by John C. Beale. 

 As part of an audit of the U.S. Environmental Protection 

Agency’s (EPA’s) vetting process for new employees, we 

looked into the EPA’s vetting of official passports.

 Issues have been identified that impact the Office of 

Inspector General (OIG) and require immediate 

attention.

14-B-0244
3

Scope and Methodology

Performed fieldwork from February 3 through March 19, 2014.

 Conducted assignment in accordance with generally 

accepted government auditing standards issued by the 

Comptroller General of the United States.

 Sought to determine whether the OIG had policies and 

procedures associated with official passports.

 Met with OIG Chief of Staff and Deputy Assistant Inspector 

General for Investigations.

14-B-0244
4

Scope and Methodology (cont’d.)

 Reviewed the EPA’s Office of International and Tribal Affairs 

(OITA) universe of official passports to determine the number of 

OIG personnel issued an official passport.

 Requested that OIG’s Office of Audit, Office of Program 

Evaluation and Office of Investigations identify OIG staff most 

likely to have an official passport.

 Contacted some current OIG employees and one prior OIG 

employee identified as being issued an official passport.

 Conducted an audit of the agency’s passport controls and will 

issue a separate report about the results. 14-B-0244
5

Criteria–Official Passport

 The Code of Federal Regulations, under 22 CFR 51.3 (b), 

provides:

An official passport is issued to an official or employee of the 

U.S. Government traveling abroad to carry out official duties.

 Under 22 CFR 51.52 (b) and (b)(1), official passports are 

exempt from fees when the individual is:

An officer or employee of the United States traveling on official 

business.... The applicant must submit evidence of the official 

purpose of the travel. 

14-B-0244
6

Criteria–Passport Acceptance Agents

 Under 22 CFR 51.22 (b)(5), the U.S. Department of State is 

authorized to select an employee of a federal agency to 

accept passport applications on its behalf.

 Within the EPA, four employees have been designated as 

passport acceptance agents:

o Two are in the OITA.

o Two are in EPA Region 5.

14-B-0244
7

Sensitive Personally 

Identifiable Information

 OITA website provides the following 

guidance: 

Official passports are controlled United States Government

documents and must be returned between trips to the Travel

Office of the Office of International and Tribal Affairs (OITA). Please

return your official passport to OITA within 15 days after

returning to the United States. When not in use for travel, all

official passports will be maintained in a secure facility within OITA.

All official passports must be forwarded to OITA for immediate

cancellation: if you retire; if you accept employment elsewhere

(even if at another government agency); or if you move to another

position within EPA that does not require official travel.

14-B-0244
8

Sensitive Personally 

Identifiable Information (cont’d.)

 Official passports are sensitive personally identifiable 

information (PII). 

 EPA Privacy Policy 2151.0 defines sensitive PII as:

Social Security numbers, or comparable identification numbers... 

Sensitive PII, a subset of PII, requires additional levels of security 

controls.

 OIG Policy 413 states:

Users must store hard copies of sensitive PII in locked file cabinets 

and limit access to only individuals who are authorized to use the 

information.

14-B-0244
9

Results

 We found the OIG is not in compliance with EPA guidance 

over the control and security of official passports issued 

to OIG employees.

 The total number of OIG employees with an official 

passport is unknown.

 The OIG does not have any policies and procedures 

associated with official passports (i.e., the issuance, 

control and security of official passports).

14-B-0244
10

How Did This Happen?

 Lack of knowledge within the OIG concerning official 

passport requirements. 

 Lack of guidance and oversight from the OITA and the OIG.

14-B-0244
11

Why Is This Important?

 Lack of compliance with OITA guidance may put the 

OIG in the position where sensitive PII is not being 

adequately protected.

 Lack of control could result in the release of sensitive 

PII due to missing, misused or improperly destroyed 

official passports.

14-B-0244
12

Total OIG Official Passports Unknown

Official passports identified

Current 

employees

Former 

employees Total

Official passports held by OIG employees 

and identified as an OIG employee by 

OITA

3 2 5

Official passports held by OIG employees 

and identified as an employee in an 

agency office by OITA

4 1 5

Official passports not in OITA records 

provided

0 1 1

TOTAL 7 4 11

 OIG has no record of who was issued an official 

passport or the passport’s status.

14-B-0244
13

Location of Official Passports

Location of passport* 

Current

employees

Former 

employees Total 

OITA Possession** 3 1 4

Traveler 4 2 6

Unknown 0 1 1

TOTAL 7 4 11

 OIG has no record of the location of official passports 

issued. According to the OITA:

* Locations is based upon OITA records.

** Location in OITA records denotes passport as being in OITA possession.

14-B-0244
14

OIG Official Passports Unknown

Based on information provided:

 We could not determine how many employees came to 

and left the OIG since OITA began compiling its records. 

 We could not determine how many employees obtained 

an official passport.

 We could not determine whether additional OIG 

employees are identified as being part of other EPA offices 

in the universe provided by OITA. 

14-B-0244
15

Lack of Policies and Procedures

 OIG does not have any policies and procedures for the 

issuance and control of official passports.

 OIG’s Office of Investigations is in the process of 

preparing a policy and procedure for official passports 

issued to its employees (that proposed procedure would 

not be applicable to the OIG as a whole).

14-B-0244
16

Lack of International Travel Coordinator

 There is no international travel coordinator within the OIG.

 The most recent OIG international travel coordinator retired over 

2 years ago.

 The international travel coordinator is the initial contact when 

developing an international travel plan and provides instruction to 

travelers on obtaining official passports.

 The Fast International Approval Tracking database indicated three 

OIG employees could have traveled internationally without having an 

official passport. U.S. Department of State policy says federal 

government employees on official international travel must travel 

with their official passport. 14-B-0244
17

Official Passport Issuance

 Any future requests for an official passport should be 

approved by the Inspector General prior to contacting 

the OITA.

o One official passport was issued in 2013 without the approval of 

OIG management. Employee followed instructions provided by 

the OITA and paid a fee for the official passport. 

o Payment of a fee defeats the benefit of an official, no-fee 

passport.

14-B-0244
18

Control and Security of Official 

Passports for Current OIG Employees

 All official passports need to be returned to the OITA 

consistent with its guidelines. 

 According to the information provided by the OITA, seven 

current OIG employees have official passports. 

o Four passports are in the possession of the employees.

o Three passports are with the OITA.

 Two official passports could not be located in the OITA’s safe.

o Both passport were in the possession of the employees.

14-B-0244
19

Proper Disposal of Official Passports

 Official passports for employees leaving the OIG need to be 

returned to the OITA. Guidelines for passport return are 

posted on the OITA website.

 We identified three employees who left the OIG with an 

official passport. 

o We were able to contact only one former employee, who stated 

that he returned his official passport when he left the OIG. 

However, there is no record that the official passport was ever 

received or disposed of in accordance with OITA guidelines. 

14-B-0244
20

Proper Disposal of Official Passports 

(cont’d.)

 OIG guidance in place at the initiation of audit fieldwork did not 

include any information concerning official passports for employees 

leaving the OIG.

 A new separation and clearance procedure dated February 27, 2014, 

was added to the OIG Intranet. The new procedure requires:

a. The OIG Office of Human Resources be made aware of its 

responsibility to contact the OITA Passport Office when an OIG 

employee is planning to separate from employment.

b. The OITA to confirm whether an official passport was issued to 

the separating employee. 

 The new procedure was not disseminated OIG-wide.

14-B-0244
21

Recommendations

1. Identify official passports issued to OIG employees. 

2. Request that all official passports be returned to the OITA for proper 

storage or cancellation. 

3. Provide the OITA with the names and available passport numbers of 

OIG employees whose passports have not been located, and 

request that the OITA notify the U.S. Department of State.

 We recommend that the Deputy Inspector General:

14-B-0244
22

Recommendations (cont’d.)

4. Develop and implement one OIG-wide policy and procedure to 

include, at a minimum:

a. Designation of an international travel coordinator position and a 

description of the coordinator’s function and responsibilities.

b. Procedures for requesting an official passport.

c. A requirement that all OIG personnel traveling outside of the 

United States on official government business obtain an official 

passport prior to traveling.

d. A requirement that upon completion of travel the official 

passport be returned in accordance with OITA guidelines.

14-B-0244
14-B-0244 23

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 21 Identify official passports issued to OIG employees. O Deputy Inspector General

2 21 Request that all official passports be returned to the 

OITA for proper storage or cancellation. 

O Deputy Inspector General 

3 21 Provide the OITA with the names and available 

passport numbers of OIG employees whose 

passports have not been located, and request that 

the OITA notify the U.S. Department of State.

O Deputy Inspector General

4 22 Develop and implement one OIG-wide policy and 

procedure to include, at a minimum:

a. Designation of an international travel 

coordinator position and a description of the 

coordinator’s function and responsibilities.

b. Procedures for requesting an official 

passport.

c. A requirement that all OIG personnel 

traveling outside of the United States on 

official government business obtain an official 

passport prior to traveling.

d. A requirement that upon completion of travel 

the official passport be returned in 

accordance with OITA guidelines.

O Deputy Inspector General

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.
14-B-0244 24

Appendix A

EPA OIG Distribution

Inspector General

Deputy Inspector General

Counsel to the Inspector General 

Deputy Assistant Inspector General for Congressional and Public Affairs