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U.S. ENVIRONMENTAL PROTECTION AGENCY

OFFICE OF INSPECTOR GENERAL

The EPA Needs to Improve 

Management of Its 

School Environmental 

Health Efforts 

Report No. 13-P-0201 March 27, 2013 

Scan this mobile 

code to learn more 

about the EPA OIG. 
 

Report Contributors: Carolyn Copper 

 Jerri Dorsey

 Jeffrey Harris 

 Natasha Henry 

 Kathryn Hess 

 Kalpana Ramakrishnan 

 Thane Thompson 

Abbreviations 

AHERA Asbestos Hazard Emergency Response Act 

CGHS Clean Green and Healthy Schools 

EISA Energy Independence and Security Act 

EPA U. S. Environmental Protection Agency 

FY Fiscal Year 

IAQ Indoor Air Quality 

IPM Integrated Pest Management 

OCHP Office of Children’s Health Protection 

OECA Office of Enforcement and Compliance Assistance 

OIG Office of the Inspector General 

Cover photo: Image is from the EPA’s Healthy School Environments website (EPA photo). 

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-0201 

March 27, 2013 Office of Inspector General 

At a Glance
 

Why We Did This Review 

The Office of Inspector General 

of the U.S. Environmental 

Protection Agency conducted this 

evaluation to determine how 

effectively the EPA ensures the 

environment in schools is healthy 

for children. Specifically, we 

looked at how the EPA 

implements its school 

environmental health programs to 

protect children’s health. 

More than 60 million students 

and teachers attend over 130,000 

public and private schools in the 

United States. Poor 

environmental conditions in 

schools can inhibit learning, 

increase absenteeism, and pose 

increased risks to children’s 

health. 

In fiscal year 2011, the agency 

launched the Clean Green and 

Healthy Schools initiative to 

support states and communities 

promoting healthier school 

environments. The initiative’s 

vision is that children “will grow, 

learn and play in clean, green, 

and healthy schools.” 

This report addresses the 

following EPA Goal or 

Cross-Cutting Strategy: 

 Working for environmental 

justice and children’s health. 

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/ 

20130327-13-P-0201.pdf 

The EPA Needs to Improve Management of Its 

School Environmental Health Efforts 

What We Found 

The EPA established children’s health as a priority. The EPA’s work on 

environmental health in schools includes educating school officials about 

asbestos risks, developing a compliance tool for schools with drinking water 

violations, and providing grants. Further, many states base their laws for indoor 

air quality in schools on the EPA’s work and tools. 

The EPA created the Clean Green and Healthy Schools initiative to promote 

healthier school environments. However, the initiative lacks necessary 

management controls to ensure that the EPA provides consistent 

implementation of the program across the United States. The agency recently 

developed some measures for the initiative, but those measures are not 

specific enough to demonstrate program outcomes. In addition, regional staff 

may not be able to collect the data needed to determine how the initiative is 

improving environmental health in schools. 

As the EPA works to improve initiative management, the agency needs to take 

into account the impact that funding reductions may have on its school 

environmental health efforts. The EPA has reduced funding for the CGHS 

initiative, as well as reduced or eliminated funding for some related school 

environmental health programs. Most notably, the EPA eliminated funding for 

its Indoor Air Quality Tools for Schools program, even though school personnel 

nationwide use the tools. Because of funding reductions, the EPA cut the 

scope of activities originally planned under the CGHS initiative, further reducing 

needed services to schools. 

Finally, the EPA did not meet all requirements of the Healthy High-Performance 

Schools subtitle of the Energy Independence and Security Act. The agency 

was nearly 3 years late issuing school environmental health guidelines for 

states, which delayed assistance to the states. The EPA also did not report 

annually, resulting in Congress being uninformed about delays.

 Recommendations and Planned Agency Corrective Actions 

The EPA should improve management controls for the CGHS initiative. This 

includes better planning, measures, and data collection procedures to ensure 

consistent regional implementation. The agency should also comply fully with 

the Energy Independence and Security Act. Finally, the EPA should regularly 

review its school environmental health programs to determine whether the 

agency provides sufficient regulatory and voluntary program services to 

address the risks to children’s health in schools. 

The agency agreed to all recommendations and provided corrective actions 

and completion dates. The recommendations remain open with corrective 

actions ongoing. No further response to this report is required. 
 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

THE INSPECTOR GENERAL 

March 27, 2013 

MEMORANDUM 

SUBJECT:	 The EPA Needs to Improve Management of Its 

School Environmental Health Efforts 

 Report No. 13-P-0201 

FROM:	 Arthur A. Elkins Jr. 

TO:	 Bob Perciasepe 

Deputy Administrator 

Jackie Mosby, Acting Director 

Office of Children’s Health Protection 

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

U.S. Environmental Protection Agency. This report describes the problems the OIG identified and 

makes recommendations to address these problems. This report represents the opinion of the OIG and 

does not necessarily represent the final EPA position. Final determinations on matters in this report will 

be made by EPA managers in accordance with established audit resolution procedures. 

Action Required 

You are not required to provide a written response to this final report, because you agreed to all 

recommendations and provided corrective actions and completion dates that meet the intent of the 

recommendations. The recommendations remain open with corrective actions ongoing. 

Should you choose to provide a response to this final report, we will post your response on the OIG’s 

public website, along with our memorandum commenting on your response. You should provide your 

response as an Adobe PDF file that complies with the accessibility requirements of Section 508 of the 

Rehabilitation Act of 1973, as amended. 

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

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

If you or your staff have any questions regarding this report, please contact Carolyn Copper, assistant 

inspector general for the Office of Program Evaluation, at (202) 566-0829 or copper.carolyn@epa.gov; 

or Jerri Dorsey, acting director for Cross Media, at (919) 541-3601 or dorsey.jerri@epa.gov. 
 

 

 

 

 

 

The EPA Needs to Improve Management of Its 13-P-0201 

School Environmental Health Efforts 

Table of Contents 

Chapters 

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

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

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

 Scope and Methodology .............................................................................. 4 

2 The EPA Should Improve Management of 

School Environmental Health Efforts............................................................... 6
 

CGHS Initiative Needs Better Planning, Implementation,

 and Guidance ........................................................................................ 6 

CGHS Initiative Planning Should Consider Reductions in

 Related Program Funding and Priority .................................................. 8 

The EPA Did Not Meet All Requirements of EISA....................................... 11 

Conclusion................................................................................................... 12 

 Recommendations ...................................................................................... 12 

Agency Response and OIG Evaluation ....................................................... 13 

Status of Recommendations and Potential Monetary Benefits.............................. 14 

Appendices 

A Agency Response to Draft Report.................................................................... 15
 

B Distribution ......................................................................................................... 19
 
 

 

Chapter 1

Introduction 

Purpose 

The Office of Inspector General of the U.S. Environmental Protection Agency 

sought to determine how effectively the EPA ensures the environment in existing 

schools is healthy for children. Specifically, we focused on whether the EPA was 

effectively implementing programs directed at existing schools, and whether the 

Office of Children’s Health had created enough program criteria to guide regional 

implementation. Further, we determined whether the EPA has data to measure 

program effectiveness, and how other programs are filling the gaps left by the 

defunding of some EPA Schools Programs over the last 5 years. 

Background 

Children are more vulnerable to harmful environmental exposures, because their 

bodies are still developing and they eat, drink, and breathe more in proportion to 

their body size. Children’s behavior also exposes them to potential hazards from 

chemicals, pesticides, and organisms. 

Children’s health has been a federal priority since 1997 when President Clinton 

signed Executive Order 13045. This order requires federal agencies to make the 

identification and assessment of children’s environmental health and safety risks a 

high priority. This order further requires that federal agencies ensure that policies, 

programs, activities, and standards address environmental health and safety risks 

to children. The EPA Administrator made leadership in children’s environmental 

health an agency priority. In a memorandum to the senior agency officers in 

February 2010, the Administrator stated: “[W]e must ensure that children's health 

protection is a driving force in our decisions.” This agency priority fulfills 

Executive Order 13045. 

The EPA’s Strategic Plan sets forth an agency commitment “to preserve the 

environment for future generations and to protect human health in the places 

where people live, work, learn, and play.” Inclusion of where people learn in this 

statement points to the key role environmental health in schools plays in 

children’s health. 

Poor environmental conditions in schools can inhibit learning, increase 

absenteeism, and pose increased risks to children’s short- and long-term health. 

Five days a week, over 54 million students from kindergarten through 12th grade 

attend more than 130,000 public and private school facilities in the United States. 

Over seven million teachers and other employees work in these schools. 

13-P-0201 1 
 

 

 

The EPA’s School-Based Efforts 

The EPA collaborates with others working to improve school environmental 

health, including children, families, teachers, school districts, advocacy 

organizations, state agencies, and other federal agencies. The EPA regulates some 

hazards in schools, such as asbestos; and assists states, school districts, and 

schools in addressing other unregulated hazards, such as mold. The EPA has 

implemented 10 programs that specifically target environmental and health risks 

in schools. The EPA features these 10 programs prominently on its “EPA Schools 

Programs” website.1 For the purpose of this evaluation, we focused on the five 

programs that contribute to improving environmental health for children in 

existing school buildings. We describe these programs and some program results 

in Table 1. 

The EPA has devoted considerable resources to educating school officials about 

the risks associated with asbestos and the management of those risks. The EPA 

also developed a compliance tool for schools with persistent drinking water 

violations. In 33 states and the District of Columbia, the EPA’s work on indoor air 

quality serves as the basis for laws requiring schools to develop and implement 

indoor air quality programs. Six of these laws specifically cite the EPA’s Indoor 

Air Quality Tools for Schools. Finally, the EPA periodically awarded grants for 

work aimed at improving school environmental health in areas such as indoor air 

quality, integrated pest management, chemical cleanout, and state environmental 

health programs. 

The OCHP within the Administrator’s office is coordinating activities across 

agency programs and regions to enhance delivery of tools to promote healthy 

school environments. Most recently, in an effort to address environmental health 

in schools, the EPA requested funds for fiscal year 2011 to launch the Clean 

Green and Healthy Schools initiative to support states and communities 

promoting healthier school environments. OCHP formed the cross-agency School 

Coordination Group to collaborate and coordinate the CGHS initiative efforts. 

The EPA’s vision for the initiative is that “children, regardless of age, race, 

economic status, or ethnicity will grow, learn and play in clean, green, and 

healthy schools.” 

To support this vision, the EPA will: 

1.	 Work to increase understanding of chemical, biological, and physical 

hazards in schools, and encourage the use of resources to create healthier 

learning environments. 

2.	 Build internal and external partnerships to support the development of 

clean, green, and healthy schools. 

1

 Healthy School Environments at http://www.epa.gov/schools/programs.html. 

13-P-0201 2 
 

 

 Table 1: EPA Environmental Health Programs Serving Existing Schools 

Program Description 

Asbestos in 

Schools 

The Asbestos Hazard Emergency Response Act became law in October 

1986 as part of the Toxic Substances Control Act. Under AHERA and its 

regulations, schools are required to determine if their facilities have 

asbestos, develop a plan to remove or manage it, and then conduct ongoing 

management and risk assessment reviews if they decide to manage the 

asbestos in place. The EPA has conducted numerous inspections of schools 

and provided compliance assistance to help schools meet the requirements 

of the AHERA regulations. 

Drinking Water in 

Schools 

Under the Safe Drinking Water Act, the water supplier is responsible for the 

quality of the drinking water. Fewer than six percent of schools in the United 

States operate their own drinking water systems. The EPA’s Office of Water 

and Office of Enforcement and Compliance Assistance worked together to 

identify schools that were out of compliance and developed a compliance 

tool for schools with persistent drinking water violations. Other efforts in 

schools to ensure safety of drinking water, such as testing for lead and other 

contaminants at drinking water faucets, are voluntary. The EPA provides 

information that assists all schools in these voluntary efforts. 

Indoor Air Quality 

Tools for Schools 

Program 

The EPA provided information and outreach to states and school districts on 

indoor air quality issues within schools for many years. Notably, the EPA 

created the Indoor Air Quality Tools for Schools and the Healthy School 

Environmental Assessment Tool. Because of these efforts, 33 States and the 

District of Columbia have established their own laws requiring that schools 

develop and implement indoor air quality programs. 

Integrated Pest 

Management in 

Schools 

Integrated Pest Management helps schools manage pests economically with 

the least possible hazard to health, property, and the environment. This effort 

includes reducing exposure to the pesticides, herbicides, and other 

chemicals used in schools and on school grounds. In November 2011, the 

EPA allocated additional funds to school IPM activities; created 10 regional 

school IPM positions; and initiated the establishment of a Center of Expertise 

in school IPM. 

Schools The EPA’s Schools Chemical Cleanout Campaign aimed to ensure that 

Chemical schools are free from hazards associated with mismanaged chemicals. The 

Cleanout EPA provided schools information and tools to manage chemicals 

Campaign responsibly, and awarded grants to clean out old laboratory chemicals. 

Source: OIG analysis of EPA and Environmental Law Institute publications and material. 

13-P-0201 3 
 

 

The Energy Independence and Security Act 

The Healthy High-Performance Schools subtitle of Title IV of the Energy 

Independence and Security Act of December 2007 tasked the EPA with four 

actions to improve school environmental health. The agency has completed three 

of the four actions. In October 2011, the EPA issued guidance on school siting. 

In September 2012, the EPA awarded five grants to states to provide technical 

assistance to schools and to develop and implement state school environmental 

health programs. In October 2012, the EPA issued guidelines for voluntary use by 

states in developing and implementing an environmental health program for 

schools. Finally, EISA required the EPA to report annually to Congress on all 

activities carried out under the Healthy High-Performance Schools subtitle. As of 

March 26, 2013, EPA has not reported to Congress. 

Scope and Methodology 

We conducted this evaluation from January 2012 to December 2012, in 

accordance with generally accepted government auditing standards. Those 

standards require that we plan and perform the evaluation to obtain sufficient, 

appropriate evidence to provide a reasonable basis for our findings and 

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

provides a reasonable basis for the results reported based upon our objectives. 

The scope of our evaluation was limited to the EPA’s programs that provide 

environmental health services to existing schools. We reviewed and assessed the 

scope, and achieved or anticipated outcomes for the 10 EPA Schools Programs 

listed on the EPA’s healthy school environments website. We determined that five 

programs fell within our scope: 

 Asbestos in Schools. 

 Drinking Water in Schools. 

 Indoor Air Quality Tools for Schools. 

 Integrated Pest Management in Schools. 

 Schools Chemical Cleanout Campaign. 

We did not review programs that address the design of new buildings to eliminate 

potential hazards, the siting of new schools to contribute to community smart 

growth efforts, the reduction of emissions from school buses, energy 

consumption, or educating students about being safe in the sun. 

The new CGHS initiative fell within our scope. In addition, we determined that 

three provisions of the EISA Healthy High-Performance Schools subtitle fell 

within our scope: 

1.	 Awarding grants to states to provide technical assistance to schools, and 

develop and implement state school environmental health programs. 

13-P-0201 4 
 

 

 

2.	 Issuing guidelines for voluntary use by states in developing and 

implementing an environmental health program for schools. 

3.	 Reporting annually to Congress on all activities carried out under the 

Healthy High-Performance Schools subtitle. 

We reviewed pertinent documents and interviewed officers, managers, and staff 

in OCHP and relevant EPA program offices. We received responses from all 10 

EPA regions to a set of questions on school programs. We also received 

information from officers of three organizations that work with the EPA and 

others to improve school environmental health: 

	 IPM Institute of North America. 

	 Healthy Schools Network. 

	 American Association of School Administrators. 

13-P-0201 5 
 

 

Chapter 2

The EPA Should Improve Management of 

School Environmental Health Efforts 

The EPA’s current school environmental health efforts need management and 

planning improvements to meet the agency priority of protecting children in the 

places where they learn. The new CGHS initiative lacks management controls and 

guidance necessary to ensure consistent implementation and data collection 

requirements to demonstrate outcomes. Further, the initiative’s new vision and 

measures documents do not ask regions to address how they will achieve results 

after the EPA reduced or eliminated funding for several existing school programs. 

Finally, the EPA was nearly 3 years late issuing school environmental health 

guidelines for voluntary use by states, and has not reported annually to Congress 

as required by EISA. Without improving the management and planning of its 

school environmental health efforts, the EPA is at risk of not executing these 

efforts in the most effective way. 

CGHS Initiative Needs Better Planning, Implementation, 

and Guidance 

The EPA created the CGHS initiative to build partnerships around healthy 

schools, increase understanding of hazards in schools, and encourage the use of 

resources to create healthier schools. We found that the initiative lacks necessary 

management controls, and the EPA has not yet developed guidelines and 

expectations that are specific enough to ensure consistent implementation. 

The EPA’s vision and measures documents outline broad expectations for the 

initiative. However, the EPA has not required regions to develop implementation 

plans, establish specific outcomes, or identify how they will collect data to 

document those accomplishments. Without specific implementation plans and 

measures, OCHP and the regions are unlikely to achieve results. Without specific 

data collection requirements, OCHP and regions are unlikely to identify, collect, 

and analyze the data needed to determine the initiative’s effectiveness. 

Initiative Lacks Guidelines for Planning, Implementation, 

and Oversight 

The CGHS initiative does not have specific implementation guidelines. 

The School Coordination Group, composed of representatives from OCHP, the 

regions, and EPA program offices, developed a Vision, Goals, Objectives, and 

Activities or “Vision” document for the initiative. The Vision document outlines 

an overall vision, general programmatic goals, and broad activities for FYs 2013 

and 2014. However, this Vision document does not take the place of specific 

implementation guidelines. Each region’s program should meet the needs of the 

13-P-0201 6 
 

 

states and school districts in their region; however, a national program also should 

have a core set of criteria that each region must meet. 

The EPA also developed the CGHS Regional FY 2013 Developmental Measures 

or “Regional Measures” document that seemed to establish a core criterion for the 

initiative: 

Improve the health of school and child care environments by supporting 

state, tribal and local efforts to address environmental health issues in 

schools and child care centers, with a focus on the poorest performing 

schools, underserved communities and tribes. 

This criterion reiterates a sub-objective in OCHP’s strategic plan. However, the 

EPA did not include this criterion in its Vision document. The EPA lays out 

headquarters and regional output measures in the Regional Measures document 

that tabulate all school activities. The Regional Measures document does not 

require separate reporting of the focus activities. Without clear criteria and 

expectations, the EPA lacks assurance that headquarters and regions will focus 

their activities on the poorest performing schools, underserved communities, and 

tribes. Further, OCHP has not posted basic initiative information on its healthy 

schools website. In our opinion, this lack of information creates challenges for 

consistently communicating with both internal and external partners. Updating the 

website would be an effective method of communicating the initiative’s vision, 

goals, and plans, and should be part of OCHP’s implementation guidelines. 

The Vision document does not require regions to develop region-specific 

implementation plans, identify specific outreach targets, or develop specific 

output and outcome levels. The EPA did not finalize the Vision document until 

October 9, 2012. Prior to this date, regional staff were unsure what the EPA 

expected them to achieve through the program. Some regions were reluctant to 

move forward in establishing their specific regional plans until the EPA finalized 

the national guidelines. However, according to the EPA’s Key Performance 

Indicators for FY 2012, the EPA was to establish implementation plans for 

OCHP and the regions by February 29, 2012. 

The CGHS initiative lacks management controls to achieve desired outcomes. 

Current EPA guidance does not require regions to develop oversight processes, 

determine what services are needed, or determine if its services are meeting those 

needs. Furthermore, the initiative does not have oversight, evaluation, or 

assessment criteria. Without criteria, the EPA cannot improve the program or 

respond to changing customer needs. Regions also are not required to gather and 

disseminate best management practices, although OCHP developed the School 

Coordination Group to share this information informally. While the EPA recently 

developed program measures, the lack of planning and implementation 

requirements prevents the EPA from determining what outcomes it has achieved. 

The EPA also cannot report which schools have reduced environmental risks to 

13-P-0201 7 
 

 

their students. As a result, the effectiveness of the CGHS initiative will remain 

unknown. 

CGHS Initiative Lacks Specific Outcome Measures 

The EPA completed its Regional Measures document on October 4, 2012. 

Regions will report the number of school decision-makers who receive 

information or participate in capacity building exercises. Regions plan to report 

the number of schools and school districts that have taken action to become 

cleaner, greener, and healthier. In addition, regions intend to track the number of 

external outreach forums or activities hosted or attended to promote the CGHS 

initiative. However, regional outcome measures are all narrative and qualitative. 

As such, the CGHS initiative lacks specific outcome measures. 

The Regional Measures document states that during the baseline developmental 

period (FYs 2012 through 2014), the EPA will work to “craft realistic measures of 

progress and effectiveness that can be used for future reporting.” However, the 

EPA has not established implementation guidelines that specify how these 

revisions will be undertaken and what information it will use. 

Before the EPA finalized the Regional Measures document, regional staff said 

that even if the EPA identified specific measures, collecting the needed data 

would be difficult. Regional staff said that without their own funding for data 

collection, they would have to rely on the data that the schools already collect. 

However, schools have very limited data collection budgets and are not always 

willing to release information to the EPA. This lack of direct data collection limits 

the EPA’s ability to determine what effects the initiative will have. It also 

prevents the EPA from knowing if the environmental health in existing schools 

has improved. As a result, the EPA will face challenges in collecting data and 

ensuring that the initiative’s activities consistently work to improve school 

environmental health for students and teachers across the United States. 

CGHS Initiative Planning Should Consider Reductions 

in Related Program Funding and Priority 

The EPA has reduced or eliminated funding for several programs working to 

improve environmental health in schools, including the new CGHS initiative and 

programs that would have worked in conjunction with the initiative. Improving 

environmental quality in schools is a partnership among federal, state and local 

agencies, as well as with nongovernmental organizations. However, since 2008, 

the EPA has cut or defunded several programs that supported those partnerships. 

For example, the EPA eliminated the School Chemical Cleanout Campaign at the 

beginning of FY 2008, reducing the EPA’s ability to help schools manage 

hazardous wastes used in science laboratories and art classrooms. Even the newly 

launched school IPM program is experiencing reductions in grants. Additionally, 

the EPA eliminated funding for the IAQ Tools for Schools program designed to 

13-P-0201 8 
 

 

improve indoor air quality, and reduced in priority another program intended to 

ensure schools manage asbestos in a safe manner. 

OCHP and regional staff informed us that the EPA does not intend the CGHS 

initiative to take the place of the reduced and defunded school programs. 

When OCHP proposed the CGHS initiative, it could not foresee the potential 

programmatic and resource voids created by the EPA’s most recent cuts to its 

mature school-related programs. Ten years ago, the Children’s Health Protection 

Advisory Committee to the EPA recommended that the EPA “[e]valuate and 

document the effectiveness of existing EPA school environmental health 

programs, such as IAQ Tools for Schools.” The EPA needs to conduct this type of 

evaluation to understand how the new initiative can improve its school 

environmental health efforts. Further, as OCHP and the regions work to improve 

their CGHS initiative planning, they need to take into account the impact that 

programmatic cuts have had on all of the EPA’s school environmental health 

efforts. 

The EPA Cut CGHS Initiative Funding 

The EPA has reduced the funding for the CGHS initiative. OCHP requested at 

least 1.1 full-time equivalent positions per region to fund regional schools 

coordinators, but could only provide funding for the fourth quarter of FY 2011. 

In FY 2012, funding levels fell to less than 50 percent of what OCHP initially 

requested. The FY 2012 cuts also reduced headquarters staff support. OCHP 

requested one position to coordinate headquarters and regional school activities 

and to establish management controls, but this position was not funded. As a 

result, the EPA cut the scope of activities originally planned under the initiative, 

further reducing needed services to schools. 

The EPA Eliminated Indoor Air Quality Tools for Schools 

OCHP launched the CGHS initiative while the EPA fully funded its IAQ Tools 

for Schools program. The organization officers we interviewed on indoor air 

quality were concerned about the elimination in FY 2012 of IAQ Tools for 

Schools and other cuts to school environmental health programs. According to 

those we interviewed in and outside the EPA and the documents we reviewed, 

school personnel nationwide used the IAQ Tools for Schools. The tools formed 

the basis for school environmental health statutes in more than 30 states. The 

EPA’s IAQ Tools for Schools program also integrated well with other EPA 

Schools Programs, such as school IPM. The program facilitated communication 

and sharing of best practices among school districts and others working to 

improve school environmental health. For example, over 2,300 teachers, school 

administrators, public health professionals, and others had been educated on 

school environmental health at the last five symposiums sponsored by the 

program. In addition, regional staff and an organization officer we interviewed 

expressed concern to us that the tools will not remain valuable assets if the EPA is 

13-P-0201 9 
 

 

 

 

not continuing to update them. OCHP and the regions will need to take into 

account the new dormant status of IAQ Tools for Schools in their CGHS initiative 

plans. 

In the absence of the IAQ Tools for Schools program, the EPA’s Indoor 

Environments Division is working on ways to provide information and support, 

and maintain communication among those working to improve indoor air quality 

in schools. This effort includes the newly developed School Health and Indoor 

Environments Leadership Development Summit. The EPA held the first summit 

on July 12, 2012, with 72 representatives from federal agencies, school districts, 

nongovernmental organizations, industry, and universities. This summit has the 

potential to fill some of the programmatic void created by the loss of the annual 

IAQ Tools for Schools symposium. However, the summit is too new to measure 

or predict outcomes, and the EPA has not defined how the summit fits within the 

CGHS initiative. 

The EPA Reduced the Priority of Asbestos Inspections 

The EPA reduced the priority of the Asbestos in Schools program for FY 2013. In 

a March 9, 2012, memorandum, the principal deputy assistant administrator of the 

OECA advised EPA regions about programs that were to have their priority and 

funding reduced, including AHERA. The EPA proposed reducing AHERA 

spending in order to increase support to other compliance monitoring and 

enforcement priorities. The March 9, 2012, disinvestment plan proposed reducing 

AHERA enforcement resources to less than a fourth of the existing level.2 

Regions would still respond to situations involving egregious violations that 

present significant risks to human health; however, most routine inspections 

would cease. 

The proposed reduction plan met with opposition from regional staff, program 

offices and others. Several regional staff informed us that this reduction would 

have a negative impact on their ability to keep children safe from asbestos. One 

regional manager told us: “With the de-funding of the AHERA Inspection 

Program, fewer schools are being inspected for compliance with the AHERA 

regulations. Hence, [fewer] school children are being protected from the potential 

exposure to asbestos.” Another regional manager said, “The continued budget 

reductions that have supported EPA’s AHERA regulatory enforcement program 

have had an adverse impact on the protection of children’s health in schools. The 

Region’s field surveillance work has found that local education agencies are not 

in compliance with the regulatory requirements of AHERA.” 

2

 The full-time equivalent level for AHERA enforcement efforts in March 2012 was 5 positions, with 0.2 in 

headquarters and 4.7 among the 10 regions. The proposed reduced level was 1.1 positions, with 0.1 in 

headquarters and 1 among the 10 regions. 

13-P-0201 10 
 

 

On June 6, 2012, the principal deputy assistant administrator, OECA, issued an 

update stating that, "[b]ased on regional and program input, OECA is no longer 

looking for a full budget adjustment plan” for AHERA. However, the 

June 6, 2012, correspondence also stated that OECA was still looking for regions 

to reduce their resources where possible. According to OECA, many schools 

successfully managed asbestos in place for decades. OECA explained that 

AHERA was a mature program that needed fewer resources to conduct 

inspections than in the past. However, the AHERA inspection is one of the few 

regulatory authorities the EPA has in schools. As such, reductions in AHERA 

inspections may increase overall environmental risks to children who attend 

primary and secondary schools, as those inspection reductions would lead to 

fewer opportunities for the EPA to be in the schools. As OECA changes 

compliance assistance or enforcement priorities for schools, OCHP and the 

regions may need to update their CGHS initiative plans to take into account these 

changes. 

The EPA Did Not Meet All Requirements of EISA 

The EPA did not meet all requirements of the Healthy High-Performance Schools 

subtitle of EISA. The EPA was nearly 3 years late issuing guidelines for voluntary 

use by states developing and implementing a comprehensive environmental health 

program for schools. EISA mandated completion of the guidelines by 

December 19, 2009; however, the EPA did not issue draft guidelines until 

February 27, 2012. The agency received public comments on these draft 

guidelines through April 20, 2012, and published the final guidelines in 

October 2012. For nearly 3 years, some regions did not begin work on state-level 

school environmental health programs because they were awaiting guidance for 

the programs. As a result, the EPA did not provide support to states in the 

timeframe specified in EISA. 

As of March 26, 2013, the EPA had made no reports to Congress on its activities 

carried out under the Healthy High-Performance Schools subtitle. EISA required 

that the EPA annually report to Congress on all activities carried out under the 

subtitle. On March 5, 2013, OCHP submitted its draft report to the Office of 

Management and Budget for review prior to issuing the report to Congress. The 

EPA failed to report to Congress on its inactivity and missed deadlines in the 

preceding 5 years. As a result, the EPA did not inform Congress and the public of 

its inaction through the required reporting process. 

13-P-0201 11 
 

 

 

Conclusion 

The EPA needs to improve program implementation planning, management, and 

oversight to advance its efforts to reduce environmental health risks in schools. 

Further, the EPA needs to consider the impacts of changes to its Schools 

Programs, such as the elimination of IAQ Tools for Schools and the decrease in 

priority of asbestos inspections, in its long-term plans for the CGHS initiative. 

Finally, the EPA needs to report to Congress on its accomplishments and delays 

under the Healthy High-Performance Schools subtitle of EISA. By taking these 

actions, the EPA can implement effective programs that it has designed to protect 

the health of children in the places where they learn. 

Recommendations 

To improve management of the EPA’s school environmental health efforts, the 

EPA Deputy Administrator should: 

1.	 Fulfill the requirement of EISA to report to Congress all activities carried 

out under the Healthy High-Performance Schools subtitle. 

The Director of the Office of Children’s Health Protection should: 

2.	 Develop implementation guidelines and management controls that 

specify how: 

a.	 OCHP will manage the adoption and implementation of the newly 

developed CGHS Vision, Goals, Objectives and Activities 

document, and the CGHS Regional FY 2013 Developmental 

Measures document. 

b.	 OCHP will continue to craft realistic measures during 

FY 2013-2014. 

3.	 Develop regional implementation guidelines and planning requirements 

for the CGHS initiative. These guidelines should: 

a.	 Include requirements for each region to develop an implementation 

plan that is consistent with the measures, strategies, and expected 

outcomes identified in the CGHS Regional FY 2013 

Developmental Measures document. 

b.	 Specify how CGHS initiative staff will coordinate better with 

internal EPA and external partners, taking into account recent 

changes in program status and funding. 

c.	 Specify how CGHS initiative staff will collect data, determine the 

programmatic success of the initiative, and modify the program to 

meet customer needs. 

13-P-0201 12 
 

 

 

4.	 Develop assessment criteria and conduct regular reviews of the EPA’s 

overall School Environmental Health programs to determine whether the 

EPA is providing sufficient regulatory and voluntary program services to 

address the risks to children’s health in schools. 

Agency Response and OIG Evaluation 

We received a response from the Deputy Administrator on January 29, 2013. 

After a meeting to discuss the response, we received an amended response from 

the acting director for OCHP dated February 12, 2013. The agency agreed to all 

four recommendations, and provided corrective actions and estimated completion 

dates that meet the intent of the recommendations. The recommendations remain 

open with corrective actions ongoing. No further response to this report is 

required. The agency’s January and February 2013 responses are included in 

appendix A. We also modified the report to address appropriate technical 

comments we received from the agency. 

13-P-0201 13 
 

 

 

 

 

 

 

 

 

 

 

 

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 

3 

12 

12 

12 

Fulfill the requirement of EISA to report to 

Congress all activities carried out under the 

Healthy High-Performance Schools subtitle. 

Develop implementation guidelines and 

management controls that specify how: 

a. OCHP will manage the adoption and 

implementation of the newly developed 

CGHS Vision, Goals, Objectives and 

Activities document, and the CGHS Regional 

FY 2013 Developmental Measures 

document. 

b. OCHP will continue to craft realistic 

measures during FY 2013-2014. 

Develop regional implementation guidelines and 

planning requirements for the CGHS initiative. 

These guidelines should: 

a. Include requirements for each region to 

develop an implementation plan that is 

consistent with the measures, strategies, and 

expected outcomes in the CGHS Regional 

FY 2013 Developmental Measures 

document. 

b. Specify how CGHS initiative staff will 

coordinate better with internal EPA and 

external partners, taking into account recent 

changes in program status and funding. 

c. Specify how CGHS initiative staff will collect 

data, determine the programmatic success of 

the initiative, and modify the program to meet 

customer needs. 

O 

O 

O 

Deputy Administrator 

Director, Office of 

Children’s Health 

Protection 

Director, Office of 

Children’s Health 

Protection 

3/31/13 

9/30/13 

9/30/13 

4 13 Develop assessment criteria and conduct regular 

reviews of the EPA’s overall School Environmental 

Health programs to determine whether the EPA is 

providing sufficient regulatory and voluntary 

program services to address the risks to children’s 

health in schools. 

O Director, Office of 

Children’s Health 

Protection 

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-0201 14 

1 
 

 

 

 

 

 

 

 

 

 

Appendix A 

Agency Response to Draft Report 

January 29, 2013 

SUBJECT: Response to the Office of lnspector General Draft Report No. OPE-FY12-0004 

"EPA Needs to Improve Management of School Environmental Health Efforts," 

December 27, 2012 

FROM: Bob Perciasepe, Deputy Administrator 

TO: Carolyn Copper, Assistant Inspector General for Program Evaluation 

Thank you for the opportunity to respond to the issues and recommendations in the report "EPA Needs 

to Improve Management of School Environmental Health Efforts." Following is a summary of the 

agency's overall position, along with its position on each of the report recommendations. For those 

report recommendations with which the agency agrees, we have provided high-level corrective actions 

and estimated completion dates. For the report recommendations with which the agency does not agree, 

we demonstrate how the recommendation has been adequately addressed. For your consideration, we 

offer the technical comments attachment to supplement this response. 

It is the EPA's position that, to date, the agency has met all requirements of the Healthy HighPerformance Schools Subtitle of Title IV of the Energy Independence and Security Act, with the 

exception of the annual report to Congress. At the time of the Office of Inspector General audit report, 

the EPA had not completed the annual report to Congress. However, the report has since been drafted, 

and the Office of Children's Health Protection will actively work to expedite internal review of the 

report and submit it to the Office of Management and Budget. Submission of the report to Congress will 

fulfill the EPA's requirement to the Energy Independence and Security Act. 

Protecting children's health and advancing environmental justice are key priorities for the EPA, and we 

are committed to reducing exposures to the environmental hazards children encounter in their daily 

lives. The EPA's mission to protect human health and the environment requires us to pay special 

attention to the vulnerabilities of those who are disproportionately affected by health challenges, 

especially our nation's children. Of particular note, the EPA's efforts toward encouraging the 

establishment of healthy school environments and meeting the requirements set forth under the Healthy 

High-Performance Schools Subtitle of Title IV of EISA are two critical examples of the type of work 

being done across the agency to protect children's health. 

The EPA considers the health of children in all actions that we undertake and will continue to coordinate 

internally across our school-related programs and with other federal agencies and external partners to 

implement our goals and measures in a manner that accurately reflects current resource levels. 

If you have any questions or need additional information, please contact either Jackie Mosby, acting 

director of the Office of Children's Health Protection, at (202) 566-0594 or mosby.jackie@epa.gov or 

Margot Brown, director of the program implementation and coordination division, at (202) 566-0874 or 

brown.margot@epa.gov. 

Attachment 

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AGENCY'S RESPONSE TO REPORT RECOMMENDATIONS 

Agreements 

No. Recommendation High-Level Intended 

Corrective Actions 

Estimated 

Completion by 

Quarter and FY 

1 Complete the requirement to EISA to 

report to Congress on all activities carried 

out under the Healthy High-Performance 

Schools Subtitle 

1. Work to expedite internal 

review of report to 

Congress and submit report 

to OMB 

2nd Quarter FY13 

3 Develop regional implementation 

guidelines and planning requirements for 

the Clean Green and Healthy Schools 

(CGHS) Initiative. The guidelines should: 

a. Include requirements for each 

region to develop and implement a 

plan that is consistent with the 

measures, strategies, and expected 

outcomes in the CGHS Regional 

FY 2013 Developmental 

Measures document 

b. Specify how the staff will better 

coordinate with EPA internal and 

external partners, taking into 

account recent changes in 

funding; and 

c. Specify how the CGHS Initiative 

staff will collect data, determine 

the programmatic success of the 

initiative, and modify the program 

to meet customer needs. 

3.a. Require regions to 

develop implementation 

plans 

4th Quarter FY13 

3.b. Partner with EPA’s 

Office of Air and 

Radiation to use the 

recently formed 

SHEILDS schools 

stakeholder network 

group to engage internal 

and external partners 

3rd Quarter FY13 

4th Quarter FY13 

3.c. Document a basic data 

collection plan (process 

may vary by region) 

2nd Quarter FY13 

4. Develop assessment criteria and conduct 

regular reviews of EPA’s overall School 

Environmental Health programs to 

determine whether EPA is providing 

sufficient regulatory and voluntary 

program services to address the risks to 

children’s health in schools. 

4.a. Assess EPA’s School 

Environmental Health 

programs through the 

existing Cross Cutting 

Fundamental Strategy 

review process (twice per 

year) 

3rd Quarter FY13 

4th Quarter FY13 

4.b. Assess EPA’s School 

Environmental Health 

programs through the 

OCHP Strategic Plan 

(with Regional Measures) 

review process (end of 

the year) 

1st Quarter FY14 

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Disagreements 

No. Recommendation Agency response 

explanation 

Proposed Alternative 

2 Develop implementation guidelines and 

management controls specify how: 

a. OCHP will manage the adoption and 

implementation of newly developed 

CGHS Vision, Goals and Objectives 

(VGO) document and CGHS Regional 

FY 2013 Developmental Measures 

documents; and 

b. OCHP will continue to craft realistic 

measures in FY 2013-2014. 

2.a. OCHP developed 

implementation 

guidelines and 

management controls 

through the schools 

Vision, Goals, and 

Objectives (VGO) 

document and the 

regional measures 

assessment document. 

OCHP will continue 

to manage the 

adoption of the 

schools VGO, OCHP 

Strategic Plan and 

Regional Measures 

through monthly 

Schools Coordinating 

Group (SCG) and 

Regional Schools 

Coordinators 

meetings. 

OCHP in consultation 

with the SCG and the 

Regions should be 

granted the 

opportunity to 

implement the VGO 

and the regional 

“realistic” measures 

that reflect available 

resources made to the 

CGHS initiative at 

both the national and 

regional level. 

2.b. OCHP Schools 

Coordinator will 

continue to work with 

Regional Schools 

Coordinators to 

implement adoption 

of realistic measures 

for FY14 

A change should be 

made in the report 

which states “OCHP 

will work with 

regions to develop 

realistic measures 

reflective of regional 

priorities and 

resources” 

13-P-0201 17 
 

 

 

 

 

 

 

 

 

 

 

 

February 12, 2013 

SUBJECT: Amendment to the Response to the Office of Inspector General Draft Report No. OPE-FY12-0004 

"EPA Needs to Improve Management of School Environmental Health Efforts", December 27, 

2012 

FROM: Jacqueline E. Mosby, MPH 

Acting Director, Office of Children’s Health 

TO: Carolyn Copper 

Assistant Inspector General, Office of Program Evaluation 

Thank you for the opportunity to discuss the issues and recommendations in the report "EPA Needs to Improve 

Management of School Environmental Health Efforts" on February 5, 2013. We have reconsidered our response to 

include the following amendment. 

Agreement 

No. Recommendation High-Level Intended Corrective 

Actions 

Estimated 

Completion by 

Quarter and FY 

2 Develop implementation guidelines and 

management controls that specify how: 

a. OCHP will manage the adoption and 

implementation of newly developed 

CGHS Vision, Goals and Objectives 

(VGO) document and CGHS Regional 

FY 2013 Developmental Measures 

documents; and 

b. OCHP will continue to craft realistic 

measures in FY 2013-2014. 

2.a. OCHP will develop an 

implementation plan to 

manage the adoption of the 

VGO and CGHS Regional 

FY 13 Developmental 

Measures. 

3rd

 Quarter FY13 

2.b. OCHP Schools Coordinator 

will continue to work with 

Regional Schools 

Coordinator to implement 

adoption of realistic 

measures for FY 14. 

4th Quarter FY13 

CONTACT INFORMATION 

If you have any questions regarding this response, please contact Khesha Reed, Associate Director of the of the 

Office of Children's Health Protection on (202) 566-0594 or Margot Brown, Director of the Program 

Implementation and Coordination Division (202)566-0874. 

cc: Margot Brown, Office of Children's Health Protection 

Khesha Reed, Office of Children's Health Protection 

Patricia Gilchriest, Office of Executive Services 

13-P-0201 18 
 

 

Appendix B 

Distribution 

Office of the Administrator 

Deputy Administrator 

Director, Office of Children’s Health Protection 

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 

Director, Office of Regional Operations 

Regional Administrators, Regions 1-10 

Office of the Administrator, Audit Follow-Up Coordinator 

Regional Audit Follow-Up Coordinators, Regions 1-10 

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