U.S. ENVIRONMENTAL PROTECTION AGENCY

OFFICE OF INSPECTOR GENERAL

Congressionally Requested 

Inquiry Into the EPA’s Use of 

Private and Alias Email Accounts 

Report No. 13-P-0433 September 26, 2013 

Scan this mobile 

code to learn more 

about the EPA OIG. 
 

 

 

 

 

Report Contributors:	 Rudolph M. Brevard 

Michael Goode 

Eric K. Jackson Jr. 

Teresa Richardson 

Gina Ross 

Sabrena Stewart 

Abbreviations 

CFR Code of Federal Regulations 

EPA U.S. Environmental Protection Agency 

GAO U.S. Government Accountability Office 

NARA National Archives and Records Administration 

NRPM National Records Management Program 

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: 

email: 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-0433 

Office of Inspector General September 26, 2013 

At a Glance 

Why We Did This Review 

We conducted this audit in 

response to a request by the 

U.S. House of Representatives 

Committee on Science, Space, 

and Technology for information 

about the U.S. Environmental 

Protection Agency’s (EPA’s) 

practices when using private and 

alias email accounts to conduct 

official business. 

The EPA’s records management 

program is managed through the 

agency’s National Records 

Management Program. The 

agency’s records officer, located 

within the Office of 

Environmental Information, 

is responsible for leading the 

program in accordance with EPA 

policy, procedures, and federal 

statutes and regulations. 

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/2013/ 

20130926-13-P-0433.pdf 

Congressionally Requested Inquiry Into the EPA’s 

Use of Private and Alias Email Accounts 

What We Found 

We found no evidence that the EPA used, promoted or encouraged the use of private 

“non-governmental” email accounts to circumvent records management 

responsibilities or reprimanded, counseled or took administrative actions against 

personnel for using private email or alias accounts for conducting official government 

business. EPA senior officials said they were aware of the agency records 

management policies and, based only on discussions with these senior officials, the 

OIG found no evidence that these individuals had used private email to circumvent 

federal recordkeeping responsibilities. 

The previous EPA Administrator and the then Acting EPA Administrator who followed 

were issued two EPA email accounts. One account was made available to the public 

to communicate with the EPA Administrator and the other was used to communicate 

internally with EPA personnel. This was the common practice for previous 

Administrators. The practice is widely used within the agency and is not limited to 

senior EPA officials. These secondary EPA email accounts present risks to records 

management efforts if they are not searched to preserve federal records. 

The agency recognizes it is not practical to completely eliminate the use of private 

email accounts. However, the agency had not provided guidance on preserving 

records from private email accounts. The EPA has not implemented oversight 

processes to ensure locations provide consistent and regular training on records 

management responsibilities, and employees complete available training on their 

delegated National Records Management Program duties. Inconsistencies in 

employee out-processing procedures pose risks that federal records are not identified 

and preserved before an employee departs the agency. EPA also lacks an automated 

tool to create federal records from its new email system. 

Recommendations and Planned Agency Corrective Actions 

We recommend that the assistant administrator for the Office of Environmental 

Information develop and implement oversight processes to update agency guidance 

on the use of private email accounts, train employees and contractors on records 

management responsibilities, strengthen relationships between federal records 

preservation and employee out processing, and deliver a system to create federal 

records from the new system. The EPA concurred with many of our 

recommendations but did ask that we clarify aspects of two findings. The agency has 

either completed recommended actions or plans to take corrective actions to address 

our findings. 

Noteworthy Achievements 

EPA created a records policy to provide guidance to personnel regarding roles and 

responsibilities for records management. In fiscal year 2009, the EPA declared 

electronic content management an agency-level weakness. In its fiscal year 2012 

Agency Financial Report, the EPA cited as part of its corrective action plan that it 

launched two pilot projects to evaluate tools for eDiscovery and the management of 

email records. Over the past 4 years, the EPA has taken various actions to close out 

this agency-level weakness. 
 

 Renee Wynn, Acting Assistant Administrator and Chief Information Officer 

Office of Environmental Information 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

THE INSPECTOR GENERAL 

September 26, 2013 

MEMORANDUM 

SUBJECT: Congressionally Requested Inquiry Into the EPA’s Use of 

Private and Alias Email Accounts 

Report No. 13-P-0433 

FROM: Arthur A. Elkins Jr. 

TO: 

This is our report on the subject audit 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 identified and the corrective actions the OIG recommends. This report represents the opinion of 

the OIG and does not necessarily represent the final EPA position. 

Action Required 

The EPA agreed with all five of our recommendations. The agency completed agreed-upon corrective 

actions associated with recommendations 1 and 2 and the OIG considers these recommendations closed. 

Recommendations 3 through 5 are considered open with agreed-upon corrective actions pending. 

We accept EPA’s response and planned corrective actions and no further response is needed.
	

If you or your staff have any questions regarding this report, please contact Richard Eyermann, the acting 

assistant inspector general for the Office of Audit, at (202) 566-0565 or eyermann.richard@epa.gov; or 

Rudolph Brevard, director for Information Resources Management Audits, at (202) 566-0893 or 

brevard.rudy@epa.gov. 
 

 

 

 

 

 

 

 

 

Congressionally Requested Inquiry Into the EPA’s 13-P-0433 

Use of Private and Alias Email Accounts 

Table of Contents 

Chapters 

1 Introduction ....................................................................................................... 1

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

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

 Noteworthy Achievements ........................................................................... 2 

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

2 The EPA’s Use of Private and Alias Email Accounts ..................................... 5
 

Results of Review ....................................................................................... 5 

 The EPA Lacks Records Management Policies and Procedures 

 Regarding Private Email Account Usage..................................... 6 

The EPA Lacks Records Management Training for 

The EPA Lacks Practices for Collecting and Preserving Records 

The EPA Lacks Tool to Place Email in Its Electronic Content 

 Private and Alias Email Usage..................................................... 7 

 Records for Employees Separating From Regional Offices......... 8 

 Management System for Its New Email System ......................... 10 

Agency Actions Prior to Issuance of Final Report ....................................... 10 

Recommendations ...................................................................................... 11 

Agency Response and OIG Evaluation ....................................................... 12 

Status of Recommendations and Potential Monetary Benefits.............................. 13
 

Appendices 

A Agency Response to Draft Report.................................................................... 14
 

B Distribution ......................................................................................................... 22
 
 

 

Chapter 1

Introduction 

Purpose 

We conducted this audit in response to a U.S. House of Representatives 

Committee on Science, Space, and Technology request for information about 

whether the U.S. Environmental Protection Agency (EPA) follows applicable 

laws and regulations when using private and alias email accounts to conduct 

official business. Specifically, in response to the committee’s request, the Office 

of the Inspector General (OIG) sought to determine whether the EPA: 

 Promoted or encouraged the use of private or alias email accounts to 

conduct official government business. 

 Reprimanded, counseled, or took administrative actions against any 

employees using private or alias email accounts. 

	 Established and implemented email records management policies and 

procedures for collecting, maintaining and accessing records created from 

any private or alias email accounts. 

	 Provided adequate training to employees concerning the use of private or 

alias email accounts to conduct official government business. 

	 Established and implemented oversight processes to ensure employees 

comply with federal records management requirements pertaining to 

electronic records from private or alias email accounts. 

Background 

National Archives and Records Administration 

The National Archives and Records Administration (NARA) is responsible for 

overseeing agencies’ adequacy of documentation and records disposition 

programs and practices. NARA issues regulations and provides guidance and 

assistance to federal agencies on ensuring adequate and proper documentation of 

the organization, functions, policies, decision, procedures and essential 

transactions of the federal government; and ensuring proper records disposition, 

including standards for improving the management of records. 

Private and Alias Email 

Private email accounts for the purposes of this review are defined as any 

non- “.gov” email addresses used to conduct EPA business. Alias email is defined 

as a secondary “epa.gov” account used to conduct EPA business. EPA stated that 

13-P-0433 1 
 

 

alias email accounts have been used by prior EPA Administrators given the large 

volume of emails sent to their public EPA accounts. 

Agency Record Management 

The EPA manages its official records through its National Records Management 

Program (NRMP). The Office of Information Collection within the EPA’s Office 

of Environmental Information oversees the NRMP. The agency records officer is 

responsible for leading the NRMP in accordance with the EPA policy, 

procedures, and federal statutes and regulations. The agency records management 

program lists the following as the agency records officer’s responsibilities: 

 Developing an overall records management strategy. 

 Producing and updating EPA records management policies, procedures, 

standards and guidance. 

 Cooperating with other units in developing policies and guidance on the 

application of technology to records management. 

 Conducting specialized briefings on records management. 

 Assisting records programs across the agency with advice and technical 

expertise. 

Noteworthy Achievements 

The EPA took steps to improve its records management practices. For example, 

the EPA created a records policy to provide guidance to personnel on the roles 

and responsibilities pertaining to records management. In addition, in fiscal year 

2009, the EPA declared electronic content management an agency-level 

weakness. In its fiscal year 2012 Agency Financial Report, the EPA stated that it 

has either completed or initiated the following corrective actions to address this 

agency-level weakness: 

 Established a new Quality Information Council Electronic Content 

Subcommittee. 

 Developed a charter for the subcommittee. 

 Established two enterprise-wide workgroups under the subcommittee. 

 Developed interim procedures to address the storage and preservation of 

electronically stored information. 

	 Launched two pilot projects to evaluate tools for eDiscovery and the 

management of email records. The results of the pilot projects will be used to 

inform the subcommittee’s decisions on future policy or tool implementation. 

The agency has also stated that it will develop a validation strategy to assess the 

effectiveness of various activities undertaken to redress the identified weakness. 

The validation strategy will consist of processes that allow the agency to review 

and determine whether policies and tools are being implemented and utilized. 

13-P-0433 2 
 

 

 

Scope and Methodology 

We conducted this audit from December 2012 to June 2013. We performed this 

audit in accordance with generally accepted government auditing standards. 

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

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

conclusions based on the audit objectives. 

To obtain a broad understanding of EPA officials records management 

responsibilities, we reviewed agency records management policies and procedures; 

the Code of Federal Regulations (CFR) in 36 CFR Chapter XII – National Archives 

and Records Administration; Office and Management Budget (OMB) Circular 

A-123, Management’s Responsibilities for Internal Control; and OMB Circular 

A-130, Management of Federal Information Resources. 

We met with the then Acting EPA Administrator (currently the Deputy 

Administrator), staff and officials from the Office of the Administrator, officials 

from the Office of General Counsel, and appointed or acting assistant and 

regional administrators from the following program and regional offices, to gather 

an understanding of their background and experience with federal records 

requirements: 

 Office of Environmental Information 

 Office of Air and Radiation 

 Office of International and Tribal Affairs 

 Office of Research and Development 

 Office of Chemical Safety and Pollution Prevention 

 Region 2, New York, New York 

 Region 3, Philadelphia, Pennsylvania 

 Region 6, Dallas, Texas 

 Region 8, Denver, Colorado 

 Region 9, San Francisco, California 

We met with offices’ information management officers, senior information 

officials, regional records officers, records liaison officers, email administrators, 

human resource directors, and Freedom of Information Act officers responsible 

for implementing and complying with the EPA federal records guidance. We also 

met with the EPA representative responsible for the direct oversight of the 

agency’s NRMP regarding that oversight and to obtain an understanding of the 

implemented internal controls around EPA’s ability to maintain electronic records 

and other records management practices. 

We also met with the former Region 8 regional administrator to gain his 

perspective on what EPA could do to strengthen its electronic records 

management practices. We requested interviews with the most recent former 

EPA Administrator and general counsel to gain their perspective on the agency’s 

13-P-0433 3 
 

 

 

 

 

records management practices. We did not receive a response from these two 

former employees on our requests for interviews. 

We followed up on the status of recommendations made by the U.S. Government 

Accountability Office (GAO) in its report National Archives and Selected 

Agencies Need to Strengthen Email Management (GAO-08-742), issued 

June 2008. The report recommended that the EPA: 

	 Revise the agency’s policies to ensure that they appropriately reflect 

NARA’s requirement on instructing staff on the management and 

preservation of email messages sent or received from nongovernmental 

email systems. 

	 Develop and apply oversight practices, such as reviews and monitoring of 

records management training and practices, that are adequate to ensure 

that policies are effective and staff are adequately trained and 

implementing policies appropriately. 

The GAO noted that the EPA was in the process of improving the implementation 

of its electronic content management system in order to collect federal records 

within the agency’s email system. 

13-P-0433 4 
 

 

 

Chapter 2

The EPA’s Use of Private and Alias Email Accounts 

The EPA lacks internal controls to ensure the identification and preservation of 

records when using private and alias email accounts for conducting government 

business. The agency lacks controls to ensure agency employees and contractors 

are trained on the records management responsibilities and a process to create 

records from its new email system. Federal guidance issued by NARA requires 

agencies to appropriately identify and preserve records for its decisions. Federal 

guidance also specifies records management training requirements as well as the 

requirements when using automated systems to preserve email records. The 

weaknesses noted occurred because the EPA had not created records management 

policies and procedures for private email account usage, and had not conducted 

oversight to ensure employees and contractors were provided consistent and 

regular training on records management responsibilities. Further, the EPA lacks 

controls to ensure out-processing procedures identify potential records, and lacks 

an automated process to create federal records from its new email system. If these 

critical issues are not corrected, the agency faces the risk that records needed to 

document the EPA’s decisions would not be available. This could potentially 

undermine the public’s confidence in the transparency of the EPA’s operations 

and ultimately erode the public’s trust in the agency’s stewardship of the nation’s 

environmental programs. 

Results of Review 

We found no evidence to support that the EPA used, promoted, or encouraged the 

use of private email accounts to circumvent records management responsibilities. 

Furthermore, EPA senior officials indicated that they were aware of the agency 

records management policies and, based only on discussions with these senior 

officials, the OIG found no evidence that these individuals had used private or alias 

email to circumvent federal recordkeeping responsibilities. We noted that the 

previous EPA Administrator and the subsequent Acting EPA Administrator 

(the Deputy Administrator) each had two EPA email accounts, one intended for 

messages from the public and one for communicating with select senior EPA 

officials. Interviews with selected assistant and regional administrators and records 

management officials disclosed that the practice of assigning personnel access to 

multiple email accounts is widely practiced within the agency. We found no 

evidence to support that the EPA reprimanded, counseled or took administrative 

actions against personnel for using private and alias email accounts. 

Personnel have access to multiple EPA email accounts for various purposes. 

These include sending out mass email notifications, transmitting or receiving 

documents in support of special projects, or linking the email account to an 

agency publicly available website to provide the public with a method to 

13-P-0433 5 
 

 

 

correspond with the EPA. Each of these additionally assigned email accounts 

could potentially contain federal records or other documents subject to Freedom 

of Information Act requests or litigation holds. Our audit disclosed that these 

secondary email accounts present risks to the agency’s records management 

efforts if they are not searched to preserve federal records. 

In addition to needed improvements over internal controls surrounding secondary 

email accounts, more oversight is needed to strengthen policies and procedures 

regarding the use of private email accounts, processes for training employees and 

contractors on their records management responsibilities, and practices for 

preserving records when employees depart the agency. The EPA should also ensure 

that it implements a tool to create records directly from its new email system. 

The EPA Lacks Records Management Policies and Procedures 

Regarding Private Email Account Usage 

The EPA lacks consistent practices regarding what steps employees should take to 

preserve federal records when they use private email accounts for conducting 

government business. Instead, in October 2012, in response to increased attention 

brought on the agency due to media articles and inquires into the EPA records 

retention practices, EPA officials placed an alert on its Intranet advising employees 

the following: 

“Do not to use any outside mail systems to conduct official Agency 

business. If, during in an emergency, you use a non-EPA email 

system, you are responsible for ensuring that any email records and 

attachments are saved in your offices’ recordkeeping system.” 

Title 36 CFR Chapter XII – National Archives and Records Administration, 

Part 1236, states that agencies that allow employees to send and receive official 

electronic mail messages using a system not operated by the agency must ensure 

that federal records sent or received on such systems are preserved in the 

appropriate agency recordkeeping system. 

The EPA had not developed or implemented policies or procedures regarding the 

preservation of email messages sent or received from private email systems. 

While the EPA alert advises employees not to use outside email systems to 

conduct official business, the alert does not instruct employees on the 

management and preservation of email messages sent from outside email systems 

if it were to occur. Senior agency officials and office representatives cited reasons 

why the complete nonuse of personal electronic equipment (which includes 

computers, mobile devices and email accounts) when the employee is not within 

the office is not practical. 

Senior agency officials and office representatives noted as one reason the 

proliferation of personal mobile devices that are not allowed access to the agency’s 

13-P-0433 6 
 

 

 

 

network. The officials also cited as another reason the increased use of unscheduled 

telework, during which employees unexpectedly worked off site when they did not 

have their assigned government equipment with them. However, given these 

growing concerns, the EPA had not taken steps to provide employees guidance as 

to when they may use private electronic equipment—including computers, mobile 

devices and email accounts—to conduct government business. 

Without effective records management policies and procedures that address 

collecting, maintaining and accessing records created from private email 

accounts, the EPA risks the possibility that agency personnel are not conducting 

government business in a manner consistent with management’s desires. The EPA 

also risks the possibility that agency personnel are not capturing potential records 

needed to document agency decisions. 

The EPA Lacks Records Management Training for Private and Alias 

Email Usage 

The EPA lacks internal controls to ensure that personnel are trained on their 

responsibilities for preserving records from private and alias accounts used to 

conduct official government business. As noted, the EPA does not have formal 

guidance on the use of private email accounts and subsequently has not provided 

training in this area. Further, the agency has not conducted training on its existing 

records management policies and procedures, which govern government records 

since 2009. Our discussion with agency representatives raises doubt as to whether 

the EPA will meet the latest requirement to inform all personnel of their records 

management responsibilities. 

Federal guidance requires training of personnel on their records management 

responsibilities. Specifically: 

	 NARA states that federal agencies must provide guidance and training to 

all agency personnel on their records management responsibilities, 

including identification of federal records, in all formats and media. 

	 OMB Circular A-123 reiterates management’s responsibility for 

establishing internal control to train personnel to possess the proper 

knowledge and skills to perform their assigned duties. OMB Circular 

A-130 requires agencies to train all employees and contractors on their 

federal records management responsibilities. 

	 OMB Memorandum M-12-18, Managing Government Records, requires 

agencies to inform employees of their records management responsibilities 

by December 31, 2014. 

The EPA had not provided records management training to employees and 

contractors in over 3 years. The agency last provided agencywide records 

13-P-0433 7 
 

 

 

management training in fiscal years 2007 and 2009. While the training discussed 

creating records within government email systems, neither of these two training 

courses addressed the usage of private email accounts to conduct official 

government business. The training also has not been updated to place emphasis on 

creating records when employees are assigned secondary email accounts. The 

agency plans to incorporate the use of private or secondary email accounts in 

future training courses to fulfill the OMB training requirement to inform 

employees of their records management responsibilities. However the agency has 

not established a firm date for when it would develop or offer the training course. 

The EPA’s NRMP did not establish controls to ensure consistent training of 

records management responsibilities within the regional and program offices or 

ensure employees with specific NRPM responsibilities took available training. 

We noted that the EPA created an organizational structure for its records 

management program with clearly defined roles and responsibilities. The EPA 

also has training available for agency records officers, liaisons and coordinators. 

However, the agency lacked processes to ensure the structure functioned as 

intended and specialized training was taken when needed. 

According to a program office records liaison officer, the officers rely upon the 

headquarters NRPM official to provide training for them to use to train their 

personnel. Records liaison officers could not provide records to show how many 

personnel within their offices were trained on records management 

responsibilities in general or specifically trained on the office’s policy on using 

personnel email accounts when conducting official government business. Our 

interviews also disclosed that the agency relies upon the records liaison officers to 

take additional training to carry out their delegated duties and the agency does not 

monitor whether the records liaison officers took training. 

The lack of consistent records management training increases the risk that agency 

employees neither understand nor fully comply with federal records management 

requirements. This also has led to records management training, when given, 

being delivered in an ad hoc and informal manner with no measure to ensure the 

information reached the specified target audience. As such, we believe the agency 

has limited assurance that all applicable personnel are trained on records 

management responsibilities, and raises questions as to whether any provided 

training was delivered in sufficient frequency to ensure personnel could 

appropriately carry out their responsibilities. 

The EPA Lacks Practices for Collecting and Preserving Records for 

Employees Separating From Regional Offices 

The EPA lacks internal controls to ensure that regional offices consistently collect 

and preserve electronic records for separating employees. Our audit disclosed that 

regional offices lacked processes for notifying individuals with records 

management responsibilities about employee separation from the agency, to 

13-P-0433 8 
 

 

 

ensure that all records were identified before the employee’s departure. 

Management at regional offices did not consistently validate that separating 

employees turned over electronic records. This included collecting and preserving 

electronic records in alias email accounts known as “mail-in accounts,” as well as 

files on flash drives and external hard drives. 

EPA Order 3110.5A and Employee Separation Checklist Form 3110-1 outline the 

agency’s employee separation procedures. The procedures state that management 

is responsible for certifying receipt of items listed on Form 3110-1, which 

includes the identification and transfer of agency records. The procedure assigns 

departing employees with responsibility to identify and transfer agency records. 

The procedure also assigns the employee’s supervisor and program office records 

manager responsibility to validate the receipt of records through signature. 

Weaknesses within regional separation procedures exist due to the NRMP 

manager not conducting oversight to ensure that federal records procedures were 

fully integrated. Our review disclosed that regional notification procedures for 

departing employees did not allow time to identify and preserve official records. 

We also found that managers with records responsibilities did not consistently 

take steps to validate collection and preservation of records before employee 

departure. For example: 

	 Regions lacked internal controls to ensure employee separation checklists 

reached individuals with records management responsibilities in order for 

them to preserve federal records. This included taking steps to have 

employees search for potential records residing within alias email 

accounts the employee manages or on other electronic media devices 

within the employee’s control. 

	 Some employees bypass their supervisor or administrative officer and go 

directly to the regional human resource office to start the separation 

process. As such, individuals tasked with records management 

responsibilities do not know that an employee is departing until the 

employee arrives with the separation checklist for clearance signature. 

	 Regional separation checklists did not include an area where regional office 

managers tasked with records management responsibilities could sign off on 

employee separation forms. Some regional separation checklist forms did 

not include an agency requirement to identify and transfer records. 

	 Regional office managers not tasked with records management 

responsibilities were signing off on employee separation forms without 

conducting steps to ensure that collection and preservation of the separating 

employees’ electronic records had occurred. One regional human resource 

staff member also stated that they typically have to sign off on employee 

clearance forms for employees who depart at the end of the year, when most 

supervisors are taking leave (use or lose) at holiday time. 

13-P-0433 9 
 

 

Without effective employee separation processes that ensure identification and 

collection of agency records from all electronic media used for collection and 

storage, the EPA risks losing historical records that support its decisions. EPA 

human resource offices are signing off that agency records were preserved even 

though they were not in a position to know this information. The weaknesses have 

also left regional counsels with insufficient time to have employees search to 

ensure that all records are preserved for ligation holds, and with the information to 

prompt employees to search for records that may be contained within alias email 

accounts, flash drives and external hard drives. 

The EPA Lacks Tool to Place Email in Its Electronic Content 

Management System for Its New Email System 

The EPA deployed its new email system without the capability to place new email 

system records in its electronic content management system. During its audit, the 

GAO noted that email records retention in the EPA was primarily a print-and-file 

system and noted that the EPA developed an oversight plan and pilot-tested a 

records management survey tool. 

Subsequent to the GAO report, in fiscal year 2009, the EPA declared electronic 

content management an agency-level weakness. In its fiscal year 2012 Agency 

Financial Report, the EPA noted that inconsistencies in how electronic content is 

maintained and stored have started to impact critical processes related to 

electronic records management. The EPA cited as part of its corrective action plan 

that it would launch two pilot projects to evaluate tools for eDiscovery and the 

management of email records. 

The EPA implemented its new email system without providing a means for agency 

employees to create federal records in the agency’s electronic content management 

system. During the past 4 fiscal years, the EPA has been taking steps to complete 

corrective actions to close out the electronic content management agency-level 

weakness by the projected completion date of fiscal year 2013. Based on 

information on the agency’s electronic content management website, employees are 

directed to print and file email records until an electronic content management 

system is in place to store records. However, the website provides no information 

as to when the EPA would provide a solution for creating federal records from its 

new email system. We believe that the EPA will not be in a position to close out 

the agency-level weakness by its projected fiscal year 2013 completion date. 

Agency Actions Prior to Issuance of Final Report 

On June 28, 2013, the EPA issued Interim Records Management Policy 

CIO 2155.2. This policy states that official agency business should first and 

foremost be done on official EPA information systems (e.g., email, instant 

messaging, computer work stations, and shared service solutions). The policy 

specifies that the record creator must ensure that any use of a non-governmental 

13-P-0433 10 
 

 

system does not affect the preservation of federal records for Federal Records Act 

purposes, or the ability to identify and process those records, if requested, under 

the Freedom of Information Act or for other official business (e.g., litigation or 

congressional oversight requests.). 

Also, on July 31, 2013, the agency deployed its new mandatory records 

management training for all agency staff, contractors and grantees that have 

access to EPA information systems. The EPA indicated that over 30 percent of 

agency employees have already taken the training. 

Recommendations 

We recommend that the assistant administrator and chief information officer, 

Office of Environmental Information: 

1.		 Develop and implement records management policies and procedures 

regarding the use of private email accounts when conducting official 

government business. 

2.		 Develop internal controls to ensure that all EPA employees and contractors 

complete training on their records management responsibilities. 

3.		 Develop and implement internal controls to monitor and track completion 

of training for personnel with specific delegated duties and 

responsibilities outlined in the NRMP guidance. 

4.		 Conduct outreach with all EPA offices to ensure that locally developed 

separation policies and procedures, as well as the associated employee 

separation checklist, include records management retention practices 

consistent with agency guidance. This should include ensuring that: 

a.		 Locations’ out-processing procedures contain practices where 

notifications are sent to individuals with records management 

responsibilities in a timely manner to aid in capturing electronic 

records from separating employees. 

b.		 Locations include steps to have employees search for potential 

records residing within alias email accounts that the employee 

manages or on other electronic media devices within the 

employee’s control. 

c.		 Locations have special out-processing procedures that contain a 

method for collecting records from departing employees during 

the holiday season or times of limited staffing. 

13-P-0433 11 
 

 

 

 

d.		 Locations update their locally developed out-processing checklist 

to ensure an area exists for where records managers can note their 

records management certifications as required by agency policy. 

5.		 Establish a revised date for when the EPA will implement an 

electronic content management tool to capture email records within the 

agency’s new email system. 

Agency Response and OIG Evaluation 

The agency provided a corrective action plan with milestones to address all the 

report recommendations. The agency completed corrective actions associated with 

recommendations 1 and 2 and the OIG considers these recommendations closed. 

Recommendations 3, 4 and 5 are considered open with corrective actions pending. 

Although the EPA agreed to perform corrective actions for our recommendations, 

the agency believed the report did not: 

	 Recognize the distinction between secondary accounts used by EPA 

Administrators for a specific purpose and secondary email accounts used 

for purposes such as sending out mass email notifications, transmitting or 

receiving documents in support of special projects, or linking the email 

account to an agency publicly available website to provide the public with a 

method to correspond with the EPA. 

	 Reflect the issuance of the EPA Interim Records Management Policy 

CIO 2155.2 on June 28, 2013, which strongly discourages the use of private 

non-EPA email accounts 

Our audit disclosed that the agency uses secondary email accounts similarly 

throughout the EPA. These secondary email accounts can send and receive email 

messages as well as create records that could be subject to Freedom of Information 

Act or litigation requests. The agency also had not implemented policies that make 

distinctions between secondary email accounts used by senior agency official and 

secondary email accounts used for other purposes. As such, we made no 

differentiation between these accounts during our audit. Our audit disclosed that 

secondary email accounts pose risks to the agency and the EPA should take steps to 

strengthen the management control structure surrounding these accounts. 

We updated the final report to recognize that the EPA issued its interim records 

management procedure subsequent to the OIG issuing its discussion draft report. 

13-P-0433 12 
 

 

 

 

 

 

 

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 

2 

11 

11 

Develop and implement records management 

policies and procedures regarding the use of 

private email accounts when conducting official 

government business. 

Develop internal controls to ensure that all EPA 

employees and contractors complete training on 

their records management responsibilities. 

C 

C 

Assistant Administrator and 

Chief Information Officer, 

Office of Environmental 

Information 

Assistant Administrator and 

Chief Information Officer, 

Office of Environmental 

Information 

6/28/13 

7/31/13 

3 

4 

5 

11 

11 

12 

Develop and implement internal controls to monitor 

and track completion of training for personnel with 

specific delegated duties and responsibilities 

outlined in the NRMP guidance. 

Conduct outreach with all EPA offices to ensure 

that locally developed separation policies and 

procedures, as well as the associated employee 

separation checklist, include records management 

retention practices consistent with agency 

guidance. This should include ensuring that: 

a. Locations’ out-processing procedures contain 

practices where notifications are sent to 

individuals with records management 

responsibilities in a timely manner to aid in 

capturing electronic records from separating 

employees. 

b. Locations include steps to have employees 

search for potential records residing within 

alias email accounts that the employee 

manages or on other electronic media devices 

within the employee’s control. 

c. Locations have special out-processing 

procedures that contain a method for 

collecting records from departing employees 

during the holiday season or times of limited 

staffing. 

d. Locations update their locally developed outprocessing checklist to ensure an area exists 

for where records managers can note their 

records management certifications as required 

by agency policy. 

Establish a revised date for when the EPA will 

implement an electronic content management tool 

to capture email records within the agency’s new 

email system. 

O 

O 

O 

Assistant Administrator and 

Chief Information Officer, 

Office of Environmental 

Information 

Assistant Administrator and 

Chief Information Officer, 

Office of Environmental 

Information 

Assistant Administrator and 

Chief Information Officer, 

Office of Environmental 

Information 

12/31/13 

12/31/13 

12/31/13 

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-0433 13 

1 
 

 

 

 

 

 

 

Appendix A 

Agency Response to Draft Report 

August 27, 2013 

MEMORANDUM 

SUBJECT: Response to the Office of Inspector General Draft Report No. OA-FY13-0113 

Congressionally Requested Inquiry into the EPA’s Use of Private and Alias Email 

Accounts, dated July 19, 2013 

FROM: Renee P. Wynn 

Acting Assistant Administrator and Chief Information Officer 

TO:	 Arthur A. Elkins, Jr. 

Inspector General 

Thank you for the opportunity to respond to the issues and recommendations described in Draft 

Report No. OA-FYI3-0113. 

Over the last several months, the agency has undertaken many important actions designed to 

improve the agency's records management and preservation program. Because of the connection 

between these efforts and some of the issues discussed in your draft report, and because we 

believe the report should be evaluated with an understanding of these efforts, I detail the efforts 

below. 

Improved Training on Information Management Responsibilities 

The EPA has launched a multi-faceted training effort to ensure every employee at the agency 

understands his or her records management responsibilities. First and foremost in the agency's 

training program is mandatory training for all employees of the EPA on records management. On 

July 31,2013, Deputy Administrator Robert Perciasepe announced the availability of this new 

training, reminding employees that "records management is the daily responsibility of every EPA 

employee." The training focuses on the foundations of records management, providing guidance 

on how to identify and preserve Federal records. Less than three weeks after the training was 

announced - and more than a month before the training must be completed on September 30, 

2013 - over 30% of agency employees have already taken the training. 

In addition to training for all employees, the EPA is working with the Department of Justice's 

Office of Information Policy on in-depth training for the agency's Freedom of Information Act 

(FOIA) professionals. The Office of Information Policy is the office within the Department of 

Justice that develops guidance for Executive Branch agencies on our responsibilities under 

FOIA, and is understood by government and non-government organizations alike as the 

government's foremost FOIA experts. The EPA is excited to welcome DOJ for this training, 

which the agency expects to conduct in September 2013. 

13-P-0433 14 
 

 

Following up on 2013's Records Management training, the EPA will conduct mandatory training 

for all of our employees on their individual and collective responsibilities ttt1der FOIA in 2014. 

This training is expected to focus on the requirements of FOIA; the importance of timely, 

accurate responses; and the role every employee plays in the agency's efforts to comply with the 

Act. In addition to these training modules, the EPA has completely overhauled our Records 

intranet site. This site, at http://intranet.epa.gov/records, serves as an agency-wide records 

management resource, and provides guidance to employees as well as links to a variety of 

information law resources. 

Updated Policies For Employee Conduct 

In addition to a renewed focus on training for employees, the EPA has begun the process of 

reviewing, updating, and reissuing agency policies for the effective management of agency 

information resources. First among that effort was a review of the agency's Records Policy, with 

the specific intent of addressing the use of personal email and consolidating our records retention 

schedules to make them easier for staff to use and more adaptable to electronic records 

management tools. 

In June 2013, the EPA issued its Interim Records Management Policy CI0-2155.2, which 

strongly discourages the use of private non-EPA email accounts, stating that "Official Agency 

business should first and foremost be done on official EPA information systems." Further, the 

Interim Policy goes on to instruct employees on how to manage and preserve email messages 

sent from outside email systems if use of a non-EPA email system were to occur. The Interim 

Policy instructs employees that once the electronic files have been captured in an approved EPA 

records management system, they should be removed from non-EPA information systems, unless 

subject to an obligation to preserve the files in their original location. The EPA initiated the 

process to finalize this policy shortly after issuing in interim form. 

On September 30th, the EPA will issue its first agency-wide Interim FOIA Procedures. The EPA 

expects these procedures will increase consistency and predictability in the processing of FOIA 

requests across the agency's programs and regions. The procedures define key roles and 

responsibilities in the processing of FOIA requests, and detail the basic steps of processing a 

request, from receipt to document collection to production. 

Advanced Technology for Managing Agency Information 

The EPA has also embarked on an ambitious effort to improve the technology available to 

employees for managing, preserving, and producing agency information. In 2010, the EPA 

established the Electronic Content Subcommittee of the Quality and Information Council. (The 

Council was established in 1999, to address enterprise-wide information management issues and 

to develop agency policies to guide the EPA in the areas of information technology and 

information management.) The Electronic Content Subcommittee was established to focus 

particularly on the challenge of creating, preserving, maintaining, and retrieving the range of 

electronic information at the agency. Under the auspices of that Committee, the agency's 

eDiscovery Workgroup led the way in launching an enterprise-wide litigation hold solution 

in October of2012. For the first time, the EPA now issues, maintains, tracks, and monitors all 

litigation holds issued to agency employees in a single system. This consolidation helps the 

13-P-0433 15 
 

 

 

agency ensure it is preserving all information subject to a litigation-based preservation 

obligation, and increases consistency and efficiency at the same time. The Workgroup has also 

made significant progress towards the full launch of electronic search and review tools that will 

be used for more comprehensive and efficient information requests and document productions. 

The agency is also poised to release an "EZ Records" tool to assist employees with their records 

management obligations. The EZ Records tool will allow employees to designate emails as 

records with just one click of a mouse, increasing the likelihood that employees will preserve 

email records as soon as they are created. To help encourage use of the tool, in October 2013, the 

EPA will launch an Agency-wide, mandatory training on how to capture email records using the 

new EPA-developed tools for records preservation. 

Response to the Draft Report 

The agency has welcomed this evaluation by the Office of Inspector General. The "Agency's 

Response to Report Recommendations" attachment details EPA's response to each 

recommendation and provides an estimated date of completion. In addition to the responses to 

the Report's specific recommendations, the agency would also like to respond to certain aspects 

of the narrative portions of the report as well. 

Specifically on the use of private, non-EPA email accounts, the report correctly finds that the 

agency has not "promoted or encouraged the use of private ' non-governmental' email accounts to 

conduct official government business." In fact, the agency has taken many steps to discourage 

the use of non-EPA email accounts unless necessitated by special circumstances. Since 2009, the 

agency has stated both in its records training for senior officials and on its records intranet site 

Frequently Asked Questions that EPA staff generally should not use non-government email 

accounts to conduct official agency business. EPA's records officer provides this information as 

part of the on-boarding process for political appointees and senior officials in Headquarters, as 

well as consults with Records Liaison Officers to provide this information to officials located in 

the agency's regional office. We believe that the report should more clearly recognize these 

previous efforts to provide guidance on this issue. In addition, the report does not reflect that all 

employees at headquarters receive basic records management training as part of the onboarding 

process, and are provided information about the extensive self-help section of the Records 

Program intranet site. 

The agency believes that the report could be more helpful for our efforts to improve our records 

management program by making a clearer distinction among the types of email accounts 

addressed in the report. The report uses both "private" and "personal" to describe email accounts 

that are not maintained on an EPA system. We encourage the OIG to use consistent 

nomenclature in the final report, to ensure all recipients of the report understand the guidance 

provided. 

We also strongly encourage the OIG to more clearly distinguish between non-EPA email 

accounts and "secondary" official epa.gov email accounts. Secondary epa.gov accounts are 

official government accounts that are assigned to an employee to a program within the EPA as 

part of that employee's or programs official government duties. Emails sent to or from these 

13-P-0433 16 
 

 

accounts are sent two or from the EPA email system in the same manner and form as an email to 

or from a "primary" account is sent to or from the EPA email system. These accounts are 

different from non-EPA email accounts, and, as such the two may require different actions to 

ensure compliance with an employee's information management responsibilities. 

Additionally, the report also seems to conflate various types of secondary official epa.gov email 

accounts. There are a variety of uses for secondary accounts that are different from a regular, day 

to day email account of a single employee. Currently, the agency has only identified a need for 

the Administrator or Deputy Administrator to have a secondary account that is specific to her or 

him and that is used as her or his day to day official government email account. These secondary, 

official government accounts permit the Administrator and Deputy Administrator to conduct 

agency business by maintaining a manageable, working email account for daily correspondence 

with staff and other officials, and the EPA's practice of issuing such accounts has been reported 

and documented to the National Archives and Records Administration (NARA) since 2008. This 

practice is appropriate and commonplace within the federal government. The Administrator's 

primary account, which is provided to the public, is rendered impractical because of the large 

volume (over 1 million emails annually) of mail it receives from outside the agency. The EPA 

actively monitors both the primary and secondary accounts, and ensures that all emails to either 

type of account are properly reviewed for preservation under the Federal Records Act and 

produced under the FOIA or other production obligation. The agency strongly believes that the 

final report should more clearly reflect the very limited existence and use of this type of 

secondary official email account. 

The other types of "secondary" accounts discussed in the report are generally not accounts 

assigned to or used by an individual employee for her day to day email communications. These 

accounts are also used for practical purposes, such as sending out mass email notifications, 

transmitting or receiving documents in support of special projects, or linking the email account 

to a publicly available website of the agency to provide the public with a method to correspond 

with the EPA. An example of this type of secondary account is the "contact us" email account for 

the EPA's Sun Wise program. This account is used to answer questions from the public about the 

Sun Wise program and is designated as Sun Wise Staff (sunwise@epa.gov) . This type of 

secondary account might be more clearly identified as a "group" account or "special purpose" 

account. We strongly believe that the final report should make this distinction, and clarify the 

draft report's conclusion that: "This practice is widely used within the agency and not limited to 

senior officials.'' My office has no information that indicates the use of "secondary" day to day 

government email accounts, such as the one used by the Administrator and which was the 

subject of the Congressional inquiry, is widely used within the agency, and the draft report does 

not include information to the contrary. 

The use of both types of secondary accounts is authorized and appropriate, therefore, the agency 

has not reprimanded, counseled, or taken administrative actions against personnel using the 

accounts for conducting official government business. Use of secondary accounts does not alter 

or interfere with the preservation requirements under the Federal Records Act or disclosure 

requirements under the Freedom of Information Act and Congressional document requests. 

Further, all agency-issued email accounts, including primary accounts and any type of secondary 

accounts, are subject to the same current agency records policies and procedures for managing 

13-P-0433 17 
 

 

records, both created and received on these accounts and are subject to the current agency 

disclosure policies for responding to information requests. In addition, the report does not 

indicate in the Scope and Methodology section that staff members who manage the 

secondary official government account assigned to the Administrator were consulted during this 

audit. I believe that these individuals may provide valuable additional information about existing 

practices and procedures for capturing and producing records from these accounts to ensure the 

agency complies with preservation and disclosure requirements. 

Finally, while the agency agrees with many of the recommendations in the report, some of the 

recommendations (specifically 3 and 4) go beyond the issue of "Private and Alias'' email account 

usage. As you can see from the information detailed above, these recommendations relate to 

issues already identified and actively being addressed by the EPA's Office of Environmental 

Information (OEI). 

Our response to your recommendations is attached. 

We look forward to discussing this report with you and to working with your office to improve 

EPA's records management program. If you have any questions regarding this response, please 

contact John Ellis, Agency Records Officer, of the Office of Information Collection/Collection 

Strategies Division/Records and Content Management Branch on (202) 566-1643. 

Attachment 

cc: Vaughn Noga 

Andrew Battin 

Jeff Wells 

John Moses 

Erin Collard 

John Ellis 

Scott Dockum 

Brenda Young 

13-P-0433 18 
 

 

 

AGENCY’S RESPONSE TO RECOMMENDATIONS: OIG Report OA-FY13-113 

No. Draft Report Recommendation Agency Response Estimated 

Completion by 

Quarter and FY 

1. Develop and implement records EPA issued an Interim Records Completed Q3 

management policies and 

procedures regarding the use of 

private email accounts when 

conducting official government 

business. (page 11) 

Management Policy CIO-2155.2, 

on June 28, 2013 which strongly 

discourages the use of private 

non-EPA email accounts and 

instructs employees on the 

management and preservation of 

FY2013 

email messages sent from outside 

email systems if it were to occur. 

EPA has initiated a process to 

In progress Q3 

FY2014 

finalize Records Management 

Policy CIO-2155.2 

2. Develop internal controls to 

ensure that all EPA employees 

and contractors complete training 

on their records management 

responsibilities. (page 11) 

EPA developed mandatory 

records management training for 

all EPA staff, contractors and 

grantees. The training was 

deployed agencywide July 31, 

2013 and is to be completed by 

September 30, 2013. 

In progress - Q4 

FY2013 

3. Develop and implement internal 

controls to monitor and track 

completion of training for 

personnel with specific delegated 

duties and responsibilities outlined 

in the National Records 

Management Program (NRMP) 

guidance. (page 11) 

Records Liaison Officers are 

required to obtain the NARA 

Certification in Federal Records 

Management. This training is 

tracked by NARA and 

periodically reported to the 

Agency Records Officers. 

Although this recommendation 

does not appear to specifically 

relate to private or secondary 

email accounts, the NRMP will 

request an updated report from 

NARA and follow-up with any 

RLO that has not received the 

certification. Non compliance 

will be reported to the 

management for appropriate 

action. 

Q1 FY2014 

4. Conduct outreach with all EPA 

offices to ensure that locally 

developed separation policies and 

procedures, as well as the 

associated employee separation 

checklist, include records 

management retention practices 

consistent with agency guidance. 

EPA’s National Records 

Management Program, via the 

Quality and Information Council’s 

agency-wide Records Workgroup, 

has been working with OARM to 

develop a consolidated employee 

separation and transfer procedure. 

Although this recommendation 

Q1 FY 2014 

13-P-0433 19 
 

 

This should include ensuring that: 

a. Locations’ out-processing 

procedures contain practices 

where notifications are sent to 

individuals with records 

management responsibilities in a 

timely manner to aid in capturing 

electronic records from separating 

employees. (page 11) 

does not appear to specifically 

relate to private or secondary 

email accounts, the procedure will 

include a requirement that 

Records Liaison Officers, Records 

Contacts and Document Control 

Staff are notified 2 weeks in 

advance of an employee’s 

separation, when possible. This 

will alert the staff with specific 

records management 

responsibilities to aid separating 

staff in capturing their records. 

4. b. Locations include steps to have 

employees search for potential 

records residing within alias email 

accounts that the employee 

manages or on other electronic 

media devices within the 

employee’s control. (page 11) 

EPA’s National Records 

Management Program, via the 

Quality and Information Council’s 

agency-wide Records Workgroup, 

and OARM will include in the 

separation process and procedures, 

steps to have employees search for 

potential records residing within 

the secondary or group email 

accounts that the employee 

manages. A checklist will also be 

provided which will include all 

possible locations where records 

(paper and electronic) might be 

found. 

Q1 FY 2014 

4. c. Locations have special outprocessing procedures that contain 

a method for collecting records 

from departing employees during 

the holiday season or times of 

limited staffing. (page 11) 

Although this recommendation 

does not appear to specifically 

relate to private or secondary 

email accounts, the EPA’s 

National Records Management 

Program, via the Quality and 

Information Council’s agencywide Records Workgroup, and 

OARM will include in the 

separation procedure safeguards to 

ensure that separating employee 

information is captured during the 

holiday season and other times of 

limited staffing. 

Q1 FY 2014 

4. d. Locations update their locally 

developed out-processing 

checklist to ensure an area exists 

for where records managers can 

note their records management 

certifications as required by 

agency policy. (page 12) 

Although this recommendation 

does not appear to specifically 

relate to private or secondary 

email accounts, the EPA’s 

National Records Management 

Program and OARM will include 

in the separation process and 

procedures an out-processing 

checklist to ensure an area exists 

Q1 FY2014 

13-P-0433 20 
 

 

for records managers to certify as 

required by policy. 

5. Establish a revised date for when 

the EPA will implement an 

electronic content management 

tool to capture email records 

within the agency’s new email 

system. (page 12) 

In addition to the Lotus Notes 

email records solution, which is 

already developed, an email 

records solution for MS Office 

365 is under development. 

Although this recommendation 

does not appear to specifically 

relate to private or secondary 

email accounts, the EPA will 

deploy agency-wide the email 

records solution for both Lotus 

Notes and MS Office 365. 

Q4 FY2013 

Q1 FY2014 

No. Findings Agency Explanation/Response Proposed Alternative 

1. The report states that, “the 

previous EPA Administrator and 

current Acting EPA Administrator 

each had two EPA email accounts, 

one intended for messages from 

the public and one for 

communicating with select senior 

officials.” (page 5) Further the 

report notes, “that the practice of 

assigning personnel access to 

multiple email accounts is widely 

practiced within the agency.” 

(page 5) 

This statement does not recognize 

the distinction between secondary 

accounts used by EPA 

Administrators for a specific 

purpose, and secondary email 

accounts used for purposes such 

as sending out mass email 

notifications, transmitting or 

receiving documents in support of 

special projects, or linking the 

email account to an agency 

publicly available website to 

provide the public with a method 

to correspond with the EPA. 

Revise the report to 

recognize this 

distinction. 

2. The report states that “EPA had 

not developed or implemented 

policies or procedures regarding 

the preservation of email 

messages sent or received from 

private email systems.” (page 6) 

Further, the report notes that 

[EPA], “...does not instruct 

employees on the management 

and preservation of email 

messages sent from outside email 

systems if it were to occur.” (page 

6) 

Please modify the statement to 

reflect the issuance of the EPA 

Interim Records Management 

Policy CIO-2155.2, on June 28, 

2013 which strongly discourages 

the use of private non-EPA email 

accounts and instructs employees 

on the management and 

preservation of email messages 

sent from outside email systems if 

it were to occur. 

EPA has initiated the process to 

finalize EPA Records 

Management Policy CIO-2155.2 

Revise the report to 

indicate that EPA put 

in place policy and 

procedures and 

training regarding the 

proper management of 

email records sent 

from private accounts. 

In progress Q3 

FY2014 

13-P-0433 21 
 

 

Appendix B 

Distribution 

Office of the Administrator 

Assistant Administrator for Environmental Information and Chief Information Officer 

Agency Follow-Up Official (the CFO) 

Agency Follow-Up Coordinator 

General Counsel 

Associate Administrator for Congressional and Intergovernmental Relations 

Associate Administrator for External Affairs and Environmental Education 

Principal Deputy Assistant Administrator for Environmental Information 

Director, Office of Information Collection, Office of Environmental Information 

Deputy Director, Office of Information Collection, Office of Environmental Information 

Audit Follow-Up Coordinator, Office Environmental Information 

13-P-0433 22