U.S. ENVIRONMENTAL PROTECTION AGENCY

OFFICE OF INSPECTOR GENERAL

Audit Follow-Up Process 

Needed for the 

U.S. Chemical Safety and 

Hazard Investigation Board 

Report No. 13-P-0128 February 1, 2013 

Scan this code to 

learn more about 

the EPA OIG. 
 

 

 

Report Contributors: Gloria Taylor-Upshaw 

 Richard Eyermann 

 Michael Davis

 Bettye Bell-Daniel 

 Michael Binder 

Abbreviations 

CSB U.S. Chemical Safety and Hazard Investigation Board 

EPA U.S. Environmental Protection Agency 

FY Fiscal Year 

GAO U.S. Government Accountability Office 

IG Inspector General 

MATS Management Audit Tracking System 

OIG Office of Inspector General 

OMB Office of Management and Budget 

Hotline 

To report fraud, waste, or abuse, contact us through one of the following methods: 

e-mail: OIG_Hotline@epa.gov write: EPA Inspector General Hotline 

phone: 

fax: 

1-888-546-8740 

202-566-2599 

1200 Pennsylvania Avenue, NW 

Mailcode 2431T 

online: http://www.epa.gov/oig/hotline.htm Washington, DC 20460 
 

 

U.S. Environmental Protection Agency 13-P-0128 

February 1, 2013 Office of Inspector General 

At a Glance
 

Why We Did This Review 

We developed this report 

based on observations made 

while preparing the 

recommended fiscal year 2012 

management challenges and 

internal control weaknesses for 

the U.S. Chemical Safety and 

Hazard Investigation Board 

(CSB). Our objective for the 

review was to assess the 

current CSB audit follow-up 

process. CSB is an 

independent federal agency 

authorized by the Clean Air Act 

Amendments of 1990. The 

Office of Inspector General 

(OIG) of the U.S. 

Environmental Protection 

Agency serves as the Inspector 

General for CSB. The OIG’s 

Office of the Chief of Staff is 

responsible for reviewing 

CSB’s performance in taking 

agreed-to corrective actions on 

OIG recommendations. 

This report addresses the 

following CSB Goal: 

 Preserve the public trust by 

maintaining and improving 

organizational excellence 

For further information, contact 

our Office of Congressional and 

Public Affairs at (202) 566-2391. 

The full report is at: 

www.epa.gov/oig/reports/2013/ 

20130201-13-P-0128.pdf 

Audit Follow-Up Process Needed for the 

U.S. Chemical Safety and Hazard Investigation Board 

What We Found 

CSB does not have a follow-up process to allow for prompt implementation of 

agreed-to OIG audit recommendations. CSB had unimplemented audit 

recommendations from an OIG fiscal year 2011 audit report for over a year past 

the agreed-to dates for implementation. Also, CSB’s tracking system did not 

assist in the prompt resolution and implementation of audit recommendations. 

By not having a follow-up process, controls over promoting efficiency and 

effectiveness within CSB’s operations are weakened. 

Office of Management and Budget (OMB) Circular A-50, Audit Follow-up, states 

that “[a]gency heads are responsible for: (1) Designating a top management 

official to oversee audit follow-up, including resolution and corrective action and 

(2) Assuring that management officials throughout the agency understand the 

value of the audit process and are responsive to audit recommendations.” In 

addition, “the audit follow-up official has personal responsibility for ensuring that 

(1) systems of audit follow-up, resolution, and corrective action are documented 

and in place, (2) timely responses are made to all audit reports, (3) disagreements 

are resolved, (4) corrective actions are actually taken, and (5) semiannual reports 

required by paragraph 8.a. (8) below are sent to the head of the agency.” 

OMB Circular A-123, Management’s Responsibility for Internal Control, Section 5, 

states “Agency managers are responsible for taking timely and effective action to 

correct deficiencies.... Management should track progress to ensure timely and 

effective results.... Management has a responsibility to complete action, in a 

timely manner, on audit recommendations on which agreement with the IG has 

been reached.” 

Recommendation 

We recommended that the CSB Chairperson develop and implement a follow-up 

system as required by OMB Circulars A-50 and A-123. CSB disagreed with our 

recommendation. 
 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

THE INSPECTOR GENERAL 

February 1, 2013 

The Honorable Rafael Moure-Eraso, Ph.D. 

Chairperson and Chief Executive Officer 

U.S. Chemical Safety and Hazard Investigation Board 

2175 K Street, NW, Suite 400 

Washington, DC 20037-1809 

Dear Dr. Moure-Eraso: 

This is our report on the audit follow-up process needed for the U.S. Chemical Safety and 

Hazard Investigation Board (CSB), based on a review conducted by the Office of Inspector 

General (OIG) of the U.S. Environmental Protection Agency. This report contains findings 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 CSB position on the subjects 

reported. CSB managers will make the final determination on matters in this report. 

CSB disagreed with both of our draft report recommendations, one of which we removed. 

Resolution efforts are in progress on the remaining recommendation. Please provide a written 

response to this final report, including a proposed corrective action, within 60 calendar days of 

the report date. We request that CSB provide in its response support for how CSB complies with 

OMB Circular A-50. The response will be posted on the OIG’s public website, along with our 

memorandum commenting on the response. The 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. The final response should not contain data that should not be released to the 

public; if the response contains such data, the data for redaction or removal should be identified. 

We have no objections to the further release of this report to the public. We will post this report 

on our website at http://www.epa.gov/oig. 

If you or your staff have any questions regarding this report, please contact Melissa Heist, 

Assistant Inspector General for Audit, at (202) 566-0899 or heist.melissa@epa.gov; or 

Michael Davis, Product Line Director, at (513) 487-2363 or davis.michaeld@epa.gov. 

Sincerely, 

Arthur A. Elkins, Jr. 
 

 

 

 

 

 

 

 

 

Audit Follow-Up Process Needed for the 13-P-0128 

U.S. Chemical Safety and Hazard Investigation Board 

Table of Contents 

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

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

Audit Follow-Up Criteria ............................................................................................ 2
 

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

Results of Review ...................................................................................................... 3
 

Recommendation ....................................................................................................... 5 

CSB Comments and OIG Evaluation ........................................................................ 5 

Status of Recommendations and Potential Monetary Benefits.............................. 7
 

Appendices 

A Status of CSB Corrective Actions to Prior Audit Recommendations ........... 8 

B CSB Response to Draft Report ......................................................................... 14
 

C Distribution ......................................................................................................... 16
 
 

 

Purpose 

While preparing the recommended fiscal year (FY) 2012 management challenges 

and internal control weaknesses for the U.S. Chemical Safety and Hazard 

Investigation Board (CSB), we noted areas of concern with CSB’s follow-up 

process and status of unimplemented audit recommendations. Our objective for 

this review was to assess the current CSB audit follow-up process. We developed 

this report so that CSB can formally address our concerns. 

Background 

CSB is an independent federal agency authorized by the Clean Air Act 

Amendments of 1990. The Act directs CSB to (1) investigate and report on the 

cause or probable cause of any accidental chemical release resulting in a fatality, 

serious injury, or substantial property damage; (2) make safety recommendations 

to reduce the likelihood or consequences of accidental chemical releases and 

propose corrective measures; and (3) establish regulations for reporting accidental 

releases. CSB became operational in January 1998. CSB’s authorizing statute 

provides for five board members, including a chairperson, all appointed by the 

President of the United States, with the consent of the Senate. As of May 2012, 

the board had 3 appointed members and a professional staff of 38. 

The Office of Inspector General (OIG) of the U.S. Environmental Protection 

Agency (EPA) assumed inspector general oversight responsibility for CSB in 

FY 2004. Previously, the Federal Emergency Management Agency and the 

U.S. Department of Homeland Security had the OIG oversight responsibility for 

CSB. The OIG’s Office of the Chief of Staff is responsible for reviewing CSB’s 

performance in taking agreed-to corrective actions on OIG recommendations 

based on requirements of the Inspector General Act, the Federal Managers’ 

Financial Integrity Act, and Office of Management and Budget (OMB) Circulars 

A-50 and A-123. 

The OIG reported in an OIG FY 2011 audit report, Chemical Safety and Hazard 

Investigation Board Did Not Take Effective Corrective Actions on Prior Audit 

Recommendations (Report No. 11-P-0115, dated February 15, 2011), that CSB 

did not take timely corrective actions to address 34 audit recommendations from 

3 OIGs and the U.S. Government Accountability Office (GAO). In four instances, 

it took CSB 4 years beyond the agreed-to corrective actions date (or report date) 

to implement corrective actions. CSB’s actions to address 13 recommendations 

were not completely effective and required additional corrective actions, and 

7 recommendations were not yet completed. The FY 2011 audit report resulted in 

seven recommendations, and one of the seven has five detailed recommended 

actions for CSB to address. 

13-P-0128 1 
 

 

 

Audit Follow-Up Criteria 

OMB Circular A-50, Audit Follow-up, affirms that corrective action by 

management on resolved findings and recommendations is essential for 

improving the effectiveness and efficiency of government operations. 

Specifically, Section 5 states: 

[e]ach agency shall establish systems to assure the prompt and 

proper resolution and implementation of audit recommendations. 

These systems shall provide for a complete record of action taken 

on both monetary and non-monetary findings and 

recommendations. 

Section 8(a) outlines numerous requirements for agency follow-up systems. It 

states that follow-up systems for resolution and corrective action must require 

prompt resolution and corrective actions on audit recommendations. Resolution 

shall be within a maximum of 6 months after issuance of a final report and 

corrective action should proceed as rapidly as possible. Also, the follow-up 

system should “[m]aintain accurate records of the status of audit reports or 

recommendations through the entire process of resolution and corrective action. 

Such records shall include appropriate accounting and collection controls over 

amounts determined to be due to the Government.” In addition, the system should 

“[p]rovide semi-annual reports to the agency head on the status of all unresolved 

audit reports over six months old, the reasons therefor[e], and a timetable for their 

resolution.” 

The Inspector General Act of 1978, as amended, states in Section 2(3) that one of 

the purposes of inspectors general is “to provide a means for keeping the head of 

the establishment and the Congress fully and currently informed about problems 

and deficiencies relating to the administration of such programs and operations 

and the necessity for and progress of corrective action.” 

GAO, in its Standards for Internal Control in the Federal Government, 

emphasizes that internal controls are a major part of managing an organization. 

OMB Circular A-123, Management’s Responsibility for Internal Control, 

Section 5, states, “[a]gency managers are responsible for taking timely and 

effective action to correct deficiencies.... Management should track progress to 

ensure timely and effective results.... Management has a responsibility to 

complete action, in a timely manner, on audit recommendations on which 

agreement with the IG has been reached. Management must make a decision 

regarding IG audit recommendations within a six month period after issuance of 

the audit report and implement management's decision within one year to the 

extent practicable.” 

13-P-0128 2 
 

 

Having an audit follow-up system is an important control that will provide an 

avenue for the agency to ensure audit recommendation implementation and the 

achievement of agency objectives. 

Scope and Methodology 

We conducted this limited-scope review from April 2012 to October 2012. We 

performed this review in accordance with generally accepted government auditing 

standards, except we did not review additional management controls, or evaluate 

unimplemented recommendations in all CSB audit reports. These limits were 

outside our scope and did not affect our review. We are reporting on our 

observations made while preparing CSB’s 2012 management challenges and 

internal control weaknesses. We believe that our observations provide a 

reasonable basis for our conclusions. 

During a meeting on CSB’s 2012 management challenges and internal control 

weaknesses, we observed that prior audit recommendations from a FY 2011 audit 

report remain unimplemented and there was no agreed-to process in place 

between the OIG and CSB to facilitate implementation. We issued a finding 

outline to CSB in May 2012. 

Our scope was limited to the current process between CSB and the OIG. We 

included the FY 2011 report’s audit recommendations and CSB’s response and 

status of those recommendations as of February 2012, and analyzed CSB’s 

responses. We reviewed OMB Circular A-50, Audit Follow-up; the Inspector 

General Act of 1978; GAO’s Standards for Internal Control in the Federal 

Government; and OMB Circular A-123, Management’s Responsibility for 

Internal Control. We held a meeting with CSB and the OIG’s Office of the Chief 

of Staff on their internal processes. We also reviewed the OIG’s FY 2011 EPA 

Semiannual Reports to Congress and accompanying Compendiums of 

Unimplemented Recommendations. 

Results of Review 

CSB does not have an agreed-to follow-up process to ensure prompt 

implementation of audit recommendations. CSB had unimplemented audit 

recommendations from an OIG FY 2011 audit report more than a year past the 

agreed-to date for implementation. Also, CSB’s tracking system did not assist in 

the prompt and proper resolution and implementation of audit recommendations. 

We believe that CSB’s lack of an audit follow-up process is an internal control 

weakness. Several authorities provide for follow-up activities for federal agencies, 

including OMB Circular A-50, the Inspector General Act, and OMB Circular 

A-123. By not having a follow-up process, controls to promote efficiency and 

effectiveness within CSB’s operations are weakened. 

13-P-0128 3 
 

 

CSB does not have a follow-up process to resolve OIG audit recommendations 

and complete corrective actions for agreed-to unimplemented recommendations. 

Since 2004, the OIG has issued 21 reports to CSB. As requested by the OIG, CSB 

provided the status of recommendations from an OIG FY 2011 audit report (see 

appendix A). As of February 2012, CSB had only implemented the agreed-to 

corrective actions for two of the seven audit recommendations (#4 and #7 in 

appendix A) and for two corrective actions for one other recommendation (#6a 

and #6b in appendix A). CSB is close to a year past the agreed-to date on fully 

implementing three of the remaining four recommendations. Our review of CSB’s 

FY 2012 status report showed that CSB changed or updated its response to two of 

four unimplemented recommendations. For one, CSB did not notify the OIG that 

it had revised a corrective action noting that completion was no longer applicable 

(#6e in appendix A). For the other, CSB noted that the recommendation (#3 in 

appendix A) should be closed but kept it open with a revised corrective action 

date because activities were planned to be completed in April 2012. Those 

activities remained unimplemented as of May 2012. 

In September 2011, we provided CSB with a spreadsheet listing the 

recommendations, due dates, status, and CSB’s action plan from its response to 

the audit report. In February 2012, CSB provided OIG an update to the 

spreadsheet noting the current status for the audit recommendations. 

CSB’s internal process included a review of the status of audit recommendations 

and follow-up with senior management around the recommendation due dates. 

In addition to the spreadsheet, CSB should have a follow-up system that should 

include at a minimum a policy, a designated audit follow-up official, roles and 

responsibilities, and reporting requirements to allow for prompt resolution of 

recommendations and implementation of agreed-to corrective actions, which is 

required by OMB Circular A-50. 

The OIG prepares a compendium of unimplemented recommendations for EPA 

on a semiannual basis to supplement our Semiannual Reports to Congress. The 

EPA compendiums highlight significant recommendations that have remained 

unimplemented past the date agreed upon by EPA and the OIG. The OIG 

considers a recommendation to be past due if the associated corrective action was 

not completed within 1 year of the original agreed-upon date or the extended date 

established by September 30, 2011. The compendium provides a listing of all of 

the other significant recommendations with future completion dates as reported in 

the EPA Management Audit Tracking System. 

In the past, for prior periods to March 31, 2012, the OIG did not prepare a 

semiannual report or compendium for CSB. The OIG’s semiannual report for 

EPA listed audit reports addressed to CSB. The compendium helps EPA 

management stay informed about outstanding commitments and its progress on 

corrective actions. For the first time, for the period April 1 through September 30, 

2012, the OIG prepared a separate semiannual report for CSB that included a list 

of “Reports With Corrective Action Not Completed.” CSB should ensure a 

13-P-0128 4 
 

 

follow-up process is in place as required by OMB Circular A-50. The lack of a 

follow-up process affects the ability of CSB to promote efficiency and 

effectiveness and to assure accountability for taking the agreed-to corrective 

actions by agreed-to dates. We consider not having a process for following up on 

recommendations to be an internal control weakness for CSB. Addressing this 

control weakness would help ensure that CSB is achieving its objectives, is 

efficiently and effectively using its resources, and is complying with OMB 

Circular A-50 and A-123. 

The OIG reported CSB’s unimplemented recommendations using an agreed-to 

interim method for tracking the status of recommendations, which is part of a 

follow-up system. During a May 2012 meeting, CSB agreed to continue to update 

the OIG’s spreadsheet for the status of unimplemented recommendations. CSB 

stills needs a complete follow-up system that addresses the requirements of OMB 

Circular A-50. 

Recommendation 

We recommend that the Chairperson, U.S. Chemical Safety and Hazard 

Investigation Board: 

1. Develop and implement a follow-up system as required by OMB Circulars 

A-50 and A-123 that includes establishing a policy that identifies an audit 

follow-up official, roles and responsibilities, required documentation, and 

reporting requirements, to allow for prompt resolution of 

recommendations and implementation of agreed-to corrective actions. 

CSB Comments and OIG Evaluation 

CSB disagreed with both of our draft report recommendations, and noted the 

following in its response: 

The CSB has reviewed draft report OA-FY12-0492 produced by 

your office. We do not concur in its findings or recommendations. 

We believe that the CSB has an adequate audit tracking system in 

place that meets the requirements of Office of Management and 

Budget (OMB) Circular A-50, “Audit Follow-Up.” As to the 

development of an audit follow-up process as recommended by 

your office, we believe that your recommendations would 

essentially substitutes (sic) the judgment of the IG for that of the 

CSB, as a collegial body, and intrude upon the CSB’s policy 

prerogatives. 

We believe that your office is simply mistaken as to the level of 

documentation and necessary actions that the CSB should take to 

review and address EPA IG recommendations. Your staff 

13-P-0128 5 
 

 

continues to insist on the development of a more formalized and 

labor-intensive tracking and follow-up process than is necessary 

for an agency with approximately 40 employees and an 

$11 million annual budget. 

We agree that a more formalized audit tracking system may be labor-intensive for 

CSB. We did not make such a recommendation in our draft report, and have 

adjusted wording in our final report to avoid such an implication. We disagree 

that CSB has an adequate follow-up process or system in place, since agreed-to 

recommendations from FY 2011 remain unimplemented in FY 2013. 

OMB Circular A-50 “provides the policies and procedures for use by executive 

agencies when considering reports issued by the Inspectors General (IGs), other 

executive branch organizations, the General Accounting Office (GAO) and nonFederal auditors where audit follow-up is necessary” and “Agency heads are 

responsible for: (1) Designating a top management official to oversee audit 

follow-up, including resolution and corrective action.” In addition, “the audit 

follow-up official has personal responsibility for ensuring that (1) systems of 

audit follow-up, resolution, and corrective action are documented and in place, 

(2) timely responses are made to all audit reports, (3) disagreements are resolved, 

(4) corrective actions are actually taken, and (5) semiannual reports required by 

paragraph 8.a. (8) below are sent to the head of the agency.” We recommended 

these requirements in recommendation 1. The OMB circular does not define 

requirements based on agency size or budget. CSB did not provide details that 

show how its current follow-up system supports these requirements, hence our 

recommendation. We request that CSB’s 60-day response include details on how 

its follow-up system meets the requirements of OMB Circular A-50. 

Recommendation 2 in our draft report was the OIG’s effort to address 

recommendations in which CSB has changed the resolution status. We have 

removed this recommendation because it is not a requirement in OMB Circular 

A-50. 

In conclusion, we disagree with CSB that many of the unimplemented 

recommendations are over-reaching; rather, they are necessary to manage CSB’s 

program operations. CSB initially agreed with the recommendations, but has since 

decided the recommendations were not necessary and left them unresolved. We 

believe that this further supports the need for CSB to appoint an audit follow-up 

official and implement a policy to address the resolution process. 

13-P-0128 6 
 

 

 

 

 

 

 

 

Status of Recommendations and 

Potential Monetary Benefits 

POTENTIAL MONETARY 

RECOMMENDATIONS BENEFITS (in $000s) 

Rec. 

No. 

Page 

No. Subject Status1 Action Official 

Planned 

Completion 

Date 

Claimed 

Amount 

Agreed-To 

Amount 

1 5 Develop and implement a follow-up system as 

required by OMB Circulars A-50 and A-123 that 

includes establishing a policy that identifies an 

audit follow-up official, roles and responsibilities, 

required documentation, and reporting 

requirements, to allow for prompt resolution of 

recommendations and implementation of agreedto corrective actions. 

U Chairperson, 

U.S. Chemical Safety and 

Hazard Investigation Board 

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 

13-P-0128 7 

1 
Status of CSB Corrective Actions to Prior Audit Recommen

Recommendations from Chemical Safety and Hazard Investigation Board Did Not Take Effective Corrective 

Actions on Prior Audit Recommendations, Report No. 11-P-0115, February 15, 2011 

# Audit Recommendations CSB Response from Final Report 

CSB 

Estimated 

Completion 

Date 

OIG 

Status Status as of Febru

1 Develop and implement a 

management control plan that documents and addresses the five internal control standards in accordance with OMB Circular A123 and GAO’s Standards for Internal Controls in the Federal Government. The plan should include an effective monitoring system to track corrective actions to address and implement audit recommendations. The plan is to include a. A database to track all prior audit recommendations, planned milestone completion dates, and corrective actions taken. b. Procedures for conducting periodic internal control reviews and properly documenting those reviews, including verifying and ensuring that audit recommendations are resolved promptly. 

We agree with the recommendation and developing a management control plan will be an initiative in our fiscal year (FY) 2011 Action Plan. 

2/28/2011 Open The management contr

developed in conjunctistrategic plan. The inteframework will stem fstrategic plan framewoSpecifically, the stratecascade into a redesignwhich will then flow to performance plans. In addition, the managplan will look at the Baddress their revision a"operating procedures" require board vote themprovide administrative staff. 

13-P-0128 
Recommendations from Chemical Safety and Hazard Investigation Board Did Not Take Effective Corrective 

Actions on Prior Audit Recommendations, Report No. 11-P-0115, February 15, 2011 

# Audit Recommendations CSB Response from Final Report 

CSB 

Estimated 

Completion 

Date 

OIG 

Status Status as of Febru

2 Develop and publish a regulation 

requiring persons to report chemical accidents, as required by the CAA (Clean Air Act). 

We agree with the recommendation and issuing a proposed rule on accident reporting will be an initiative in our FY 2011 Action Plan. 

9/30/2011 Open After further consideri

CSB believes that it reincident notifications tmedia and Internet seaexisting Federal sourceNational Response CeCSB recorded 282 higincidents using these dthese, CSB deployed ifive sites. Accordinglyconsult with its congrecommittees of jurisdicApril 30, 2012, requesclarification on whethedesire to preserve the mexisting statute. In addprelude to a possible rethe CSB will develop a questions to be sent to have experienced incidResponses to the letter design of a future repoletter will be develope2012. 

13-P-0128 
Recommendations from Chemical Safety and Hazard Investigation Board Did Not Take Effective Corrective 

Actions on Prior Audit Recommendations, Report No. 11-P-0115, February 15, 2011 

# Audit Recommendations CSB Response from Final Report 

CSB 

Estimated 

Completion 

Date 

OIG 

Status Status as of Febru

3 Follow up with Congress on the 

CSB request for clarification of its statutory mandate. Upon receipt of the response, develop a plan to describe and address the investigative gap, address prior audit recommendations and request the necessary resources to meet CSB’s statutory mandate. 

We agree with the recommendations. Under our 2011 action plan, we will transmit a formal package of suggested legislative improvements to the CSB’s Congressional authorizing committees. The package will include language to clarify the statutory mandate to investigate [chemical accidents]. The CSB is not in a position, however, to guarantee a Congressional response as indicated in the OIG recommendation. 

4/30/2011 Open CSB believes this reco

should be closed since statutory issue with Coin November 2009. In letter from then-Chairmstated, "Pending any fufrom Congress, the CSto adhere to its interprestatutory authority and Nonetheless, CSB will relevant committees of it writes concerning thrule, by April 30, 2012

4 Ensure that the responsibilities of 

the Managing Director include: 

We agree with the recommendation. We will 

3/31/2011 Closed 4a was completed in Ja

a. Establishing performance goals, review the Managing Director’s 4b is addressed as part holding program managers position description and make Capital Plan (see recomaccountable for meeting those goals, and demonstrating improvement in the Board’s ability to meet it statutory mandates over time, as recommended by GAO. b. Developing and implementing an executive succession and transition planning strategy that ensures a sustained commitment and continuity of leadership operations. 

any necessary modifications to ensure these responsibilities are included. 

completed November 

13-P-0128 
Recommendations from Chemical Safety and Hazard Investigation Board Did Not Take Effective Corrective 

Actions on Prior Audit Recommendations, Report No. 11-P-0115, February 15, 2011 

# Audit Recommendations CSB Response from Final Report 

CSB 

Estimated 

Completion 

Date 

OIG 

Status Status as of Febru

5 Develop and implement a system 

for periodic reviews of Board Orders to ensure they remain updated (i.e., effective date of the policy and scheduled review date) and include the requirement for such a system in the management control plan. 

We agree with the recommendation. A system for periodic reviews of Board Orders will be developed and included in the management control plan. 

2/28/2011 Open See recommendation # 

6a Take corrective actions that will We agree with the 3/31/2011 Closed Amendments to Board 

satisfy prior audit recommendations recommendation. Specifically, were approved by notaby updating and formalizing Board Orders that are essential to facilitate and manage effective and efficient control activities. Specifically, update: Board Order 036, “Incident Selection Process,” to reflect current changes, such as its data sources, changes due to technology improvements, and the incident selection process decision-making flowchart, to improve the incident screening and deployment decisionmaking process. In addition, formalize the Incident Screeners Guide. 

updating Board Order 036 will be included as an initiative in our FY 2011 action plan 

on February 6, 2012. 

13-P-0128 
Recommendations from Chemical Safety and Hazard Investigation Board Did Not Take Effective Corrective 

Actions on Prior Audit Recommendations, Report No. 11-P-0115, February 15, 2011 

# Audit Recommendations CSB Response from Final Report 

CSB 

Estimated 

Completion 

Date 

OIG 

Status Status as of Febru

6b Board Order 040, “Investigation 

Protocol,” to govern employees retaining memberships in societies or organizations to which the CSB issues recommendations. 

We agree with the recommendation. Specifically, we will either update Board Order 40 or develop a specific Board Order to address employee participation and memberships in professional associations. 

9/30/2011 Closed Board Order 040 was a

notation item 894 on D2011, to address emplomemberships in outsidto which the CSB may recommendations. 

6c Board Order 027, “Roles, 

Responsibilities, and Standards of Conduct in Procurement Activities,” to reflect current procurement practices and processes to ensure consistency in the procurement process. 

We agree with the recommendation. Specifically, improving the procurement program will be an initiative in the FY 2011 Action Plan. As part of this initiative, we will update Board Order 027 as appropriate. 

3/31/2011 Open CSB is analyzing a wa

administratively correcwhen offices or positioeliminated. Responsiblikely be transferred baChairperson who can rappropriate. 

6d Board Order 022, 

“Recommendation Program,” to include new practices adopted for following up on safety recommendations, to include a quality review program to ensure timely follow-up on closed safety recommendations. 

We agree with the recommendation. Specifically, Board Order 022, “Recommendations Program,” is currently under review and we will consider including a quality review program to ensure timely follow-up on safety recommendations. We are also updating our Recommendation Office “Standards of Practice” document and expect that the Board Order will contain general guidance and the Standards of Practice will include detailed procedures. 

9/30/2011 Open Awaiting new OIG aud

recommendations on thRecommendation ProgBoard Order 022 can hcomprehensive revisio

13-P-0128 
Recommendations from Chemical Safety and Hazard Investigation Board Did Not Take Effective Corrective 

Actions on Prior Audit Recommendations, Report No. 11-P-0115, February 15, 2011 

# Audit Recommendations CSB Response from Final Report 

CSB 

Estimated 

Completion 

Date 

OIG 

Status Status as of Febru

*6e Board Order 028, “Executive 

Administrative Functions of the Board,” to document the role and responsibility of the Managing Director position. 

We agree with the recommendation. Specifically, we will review Board Order 028, and update it as appropriate to reflect the role and responsibility of the Managing Director position. 

9/30/2011 Open The CSB reviewed Bo

and determined that it appropriate to documethe responsibilities of tDirector in this Board purpose of the Board Oestablish the manner in exercises its executive administrative functionposition of the ChairpeThe Managing Directoposition, for which rolresponsibilities are appestablished in the posit

7 Finalize and issue the human 

capital plan currently under development. 

We agree with the recommendation. Updating and approving the human capital plan is an initiative in our FY 2011 Action Plan. 

1/31/2011 Closed The Human Capital Pl

approved by notation iNovember 16, 2011. 

* CSB determined that this recommendation was no longer applicable 

13-P-0128 
 

 

Appendix B 

CSB Response to Draft Report 

November 26, 2012 

Honorable Arthur A. Elkins, Jr. 

Inspector General 

U. S. Environmental Protection Agency 

Washington, DC 20460 

Re: U.S. Chemical Safety and Hazard Investigation Board (CSB) Response to EPA 

OIG Project No. OA-FY12--0492 

Dear Mr. Elkins: 

The CSB has reviewed draft report No. OA-FY12-0492 produced by your office. We do not 

concur in its findings or recommendations. We believe that the CSB has an adequate audit 

tracking system in place that meets the requirements of Office of Management and Budget 

(OMB) Circular A-50, “Audit Follow-Up.” As to the development of an audit follow-up process 

as recommended by your office, we believe that your recommendations would essentially 

substitute the judgment of the IG for that of the CSB, as a collegial body, and intrude upon the 

CSB’s policy prerogatives. 

We believe that your office is simply mistaken as to the level of documentation and necessary 

actions that the CSB should take to review and address EPA IG recommendations. Your staff 

continues to insist on the development of a more formalized and labor-intensive tracking and 

follow-up process than is necessary for an agency with approximately 40 employees and an $11 

million annual budget. Indeed, we perceive layer upon layer of bureaucratic burdens proposed 

by your office, with little focus on anything that might actually assist the agency in its mission. 

Moreover, we note that none of the IG’s audit findings have any potential monetary impact, and 

we believe that many of the “unimplemented recommendations’ unnecessarily delve into matters 

that go beyond management efficiency issues and intrude upon Board’s substantive mission and 

program. 

For example, the IG’s recommendation that the Board seek Congressional clarification of its 

statutory mandate – concerning whether the CSB is hypothetically required to investigate all 

accidental chemical releases in its jurisdiction – is not a management deficiency. That represents 

a policy judgment that the CSB does not agree with. Similarly, the IG’s recommendation that 

the CSB publish a chemical incident reporting rule, while perhaps having merit, represents not a 

management deficiency, but the substitution of the IG’s judgment for that of the CSB. 

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To the extent that your office continues to insist on “form over substance” in its evaluation of the 

CSB’s work, and the substitution of its judgment for that of the CSB as a whole, we will 

continue to respectfully nonconcur in the recommendations your have proffered. 

Sincerely, 

/Signed/ 

Rafael Moure-Eraso, Ph.D. 

Chairperson 

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Appendix C 

Distribution 

Chairperson and Chief Executive Officer, U.S. Chemical Safety and Hazard Investigation Board 

Managing Director, U.S. Chemical Safety and Hazard Investigation Board 

Deputy Managing Director, U.S. Chemical Safety and Hazard Investigation Board 

Counselor to the Chair, U.S. Chemical Safety and Hazard Investigation Board 

Director of Administration and Audit Liaison, U.S. Chemical Safety and Hazard 

Investigation Board 

General Counsel, Office of General Counsel, U.S. Chemical Safety and Hazard 

Investigation Board 

Director, Office of Recommendations, U.S. Chemical Safety and Hazard Investigation Board 

Communications Manager, Office of Congressional, Public, and Board Affairs, 

U.S. Chemical Safety and Hazard Investigation Board 

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