United States General Accounting Office

GAO Report to the Chairman, Subcommittee

on Civil Service, Committee on

Government Reform and Oversight

House of Representatives

June 1997 PERSONNEL

PRACTICES

Improper Personnel

Actions on Selected

CPSC Appointments

GAO/GGD-97-131

GAO United States

General Accounting Office

Washington, D.C. 20548

General Government Division

B-276748 

June 27, 1997

The Honorable John L. Mica

Chairman, Subcommittee on Civil Service

Committee on Government Reform and Oversight

House of Representatives

Dear Mr. Chairman:

Your July 23, 1996, letter requested that we investigate alleged improper

personnel activities at the Pension Benefit Guaranty Corporation (PBGC)

and the Consumer Product Safety Commission (CPSC). More specifically,

you were concerned about alleged improper hirings of former Internal

Revenue Service (IRS) employees by PBGC and alleged improper personnel

actions and “burrowing in” by political appointees at CPSC.

1

 We reported on

the results of our work at PBGC in October 1996.2

 This report provides the

results of our work at CPSC.

The original objective of our work at CPSC was to determine whether the

appointments of six individuals who were the subjects of the allegations

received by your office were made in accordance with merit system

principles and applicable rules and regulations. As we conducted our audit

work and at your request, we added an objective to identify the number of

appointments that CPSC had made at advanced rates of pay (pay at a level

higher than the minimum for the position’s grade) during the period

beginning in March 1994 when the current CPSC Chairman assumed office,

and ending in March 1997; and to determine whether the justification for

those rates was documented as required by federal regulations.

Results in Brief The allegations concerning the six appointments proved to be partially

true. The appointments did not, as alleged, constitute burrowing in

because the individuals did not convert from noncareer political

appointments to career appointments in the competitive service.3

 Each of

the appointments was beset, however, by one or more irregular or

improper personnel actions. These included (1) three instances in which

proper candidate examination and selection procedures were not

1

“Burrowing in” is a term generally used to refer to the conversion of former political appointees to

career status in the competitive service.

2

Hiring of Former IRS Employees by PBGC (GAO/GGD-97-9R, Oct. 2, 1996).

3

The six allegations involved one noncareer, Schedule C political appointment; one career

appointment based on the individual’s eligibility due to prior service in the legislative branch; three

noncareer, term appointments lasting up to 2 years; and one noncareer, temporary appointment.

Page 1 GAO/GGD-97-131 Personnel Practices
B-276748 

followed, causing, in two cases, veterans with veterans preference

eligibility to be denied proper consideration in the selection process;

(2) three instances in which advanced rates of pay based on superior

qualifications were set without the required documentation to justify such

rates; and (3) two instances in which the proper use of term appointment

authority was questionable.

In December 1996, we asked the Office of Personnel Management (OPM),

which is responsible for overseeing the federal personnel system, to

review our findings for the six appointments and, if those findings were

accurate, to tell us what corrective actions it would instruct CPSC to take.

OPM generally agreed with our findings and directed CPSC to take certain

actions, such as to notify the veterans that they are to receive priority

consideration for the next positions that become available that are similar

to those for which they had applied. CPSC took the instructed steps and

reported to OPM in April 1997. OPM subsequently notified CPSC on May 28,

1997, that it was satisfied with the actions taken.

CPSC made 20 additional appointments between March 1994 and

March 1997 in which, according to CPSC data, the appointees received

advanced rates of pay. In 2 of the 20 cases the individuals had resigned

from CPSC, and their official personnel folders (OPFs) were not readily

available. Of the remaining 18 appointments, 9 were based on the superior

qualifications of the appointees and 8 were based on previous salary levels

of the appointees. In the one remaining case, the basis for the advanced

rate of pay could not be determined. Supporting documentation for five of

the nine superior qualification appointments was in the appointees’ OPFs.

Supporting documentation for the other four was not present. CPSC

officials said that they have since prepared, or are preparing, supporting

justification for these four. Supporting documentation existed in the OPFs

of the eight appointees whose salary was set based on their highest

previous salary levels.

CPSC officials attributed the irregular or improper personnel actions to

administrative error and misunderstandings by its personnel staff and said

that the agency has taken steps to improve its personnel operations.

According to CPSC’s personnel director, additional training is being

provided to personnel staff, internal controls are being enhanced, and

guidelines are being written to help ensure that future personnel actions

are conducted properly.

Page 2 GAO/GGD-97-131 Personnel Practices
B-276748 

In February 1996, OPM delegated to CPSC the authority to conduct open,

competitive examinations for entry to various CPSC positions and from the

results of those entry examinations, develop lists of qualified applicants.

Given the problems CPSC has had in properly carrying out personnel

actions, it is important that CPSC is successful in improving its personnel

operations and is able to competently handle its delegated authority. OPM

is responsible for ensuring that CPSC exercises its delegated authority in

full compliance with merit system principles, rules, and regulations. The

primary way OPM ensures such compliance is by conducting oversight

reviews. An OPM official told us that the agency plans to conduct such a

review of CPSC in 1998.4

Background CPSC is an independent federal agency established by the Consumer

Product Safety Act (P.L. 92-573) with the mission to reduce unreasonable

risks of injury and deaths associated with consumer products. As an injury

prevention agency, CPSC is to research product hazards, participate with

industry in developing voluntary standards for products, issue and enforce

mandatory standards, and inform the public of potential product hazards.

CPSC also is to direct the recall of dangerous products and enforce its

statutes in administrative and federal court proceedings.

The authorizing legislation provides for the appointment of five

commissioners by the President for staggered 7-year terms. As of

June 1997, CPSC had three commissioners, one of whom was designated

CPSC Chairman. The Chairman is the principal executive officer of CPSC,

with authority to exercise all executive and administrative functions of the

agency. Personnel operations are to be conducted by a staff of nine

employees. During fiscal year 1997, CPSC has hired approximately 40

individuals.

CPSC received appropriations of approximately $42.5 million for fiscal

years 1994 and 1995 and about $40 million for fiscal year 1996. Its

personnel ceiling was 511 full-time equivalent (FTE) positions in fiscal year

1994 and 487 FTE positions in fiscal years 1995 and 1996.

Scope and

Methodology

To determine whether the six appointments that were the subject of

allegations were made in accordance with merit system principles and

applicable rules and regulations, we (1) identified the appointment

4

A CPSC official told us that the agency plans to contract with OPM by July 1997 for an independent

audit of CPSC’s use of delegated examining authority. Such an audit would be in addition to the

planned oversight review by OPM in 1998.

Page 3 GAO/GGD-97-131 Personnel Practices
B-276748 

procedures followed, as documented in the OPFs and in CPSC’s merit

staffing case files5

 for each appointment, and (2) reviewed the procedures

in light of merit system principles and applicable federal personnel rules

and regulations. We interviewed CPSC personnel and management officials

to discuss questions we developed on each case. We also provided our

case summaries, including the problems we identified, to OPM and asked

whether it agreed with our findings and, if so, what corrective actions OPM

intended to instruct CPSC to take. We discussed and clarified OPM’s

response, where necessary, with officials from that agency.

To identify the number of appointments that CPSC had made at advanced

rates of pay during the period March 1994 through March 1997, and to

determine whether the justification for those rates was documented as

required by federal regulations, we obtained a listing from CPSC of

appointments made during this period with advanced salary rates. The

listing contained the names of three individuals who were part of the six

appointments that were the subjects of allegations of improper personnel

actions and burrowing in, and whose advanced pay rates we had already

reviewed. After subtracting those 3 from the listing, 20 others remained.

We reviewed the OPFs of 18 of the 20 to determine whether the required

documentation to justify the advanced rates was present. The other two

appointees had resigned from CPSC, and their OPFs had been sent to the

Federal Records Center and were not readily available.

We did not verify the completeness of CPSC’s listing of those appointments

involving advanced salary rates. We also did not attempt to reach

conclusions about the quality or sufficiency of the written justifications in

those cases in which written justifications were present.

During our review, CPSC obtained OPM’s assistance in reviewing

appointments and promotion actions taken by CPSC during the period

March 10, 1994, through October 31, 1996. OPM also reviewed the

appointments of senior executive and Schedule C employees on board at

the time OPM provided the assistance. We discussed this work with OPM and

CPSC officials, reviewed a summary of observations made by OPM on the

results of its review, and discussed with CPSC’s personnel director actions

planned and taken to improve personnel operations.

5

Merit staffing case files contain information related to the competitive examining process used in

filling a position. The kind of information generally contained includes a copy of the vacancy

announcement, the application packages of each applicant, the results of the entry examinations and

the rating panel, the listing of qualified applicants, and documentation showing which applicant was

selected for the position.

Page 4 GAO/GGD-97-131 Personnel Practices
B-276748 

We did our work in Washington, D.C., from August 1996 to June 1997 in

accordance with generally accepted government auditing standards. We

requested comments on a draft of this report from the Chairman of CPSC

and the Director of OPM. CPSC provided written comments, and OPM

provided comments orally. Their comments are discussed at the end of

this letter, and CPSC’s written comments are reprinted in appendix III.

Problems Identified

With Appointments

Made by CPSC

Each of the six appointments we reviewed and that were the subject of

allegations—while not involving burrowing in—involved one or more

irregular or improper personnel actions. OPM generally agreed with our

findings. Also, our review of an additional 18 appointments showed that in

9 cases, advanced salaries were provided due to the superior qualifications

of the individuals. However, written justification to support the superior

qualifications—as required by regulations—did not exist in four of the

nine cases. CPSC officials told us that corrective actions have been, or are

being, taken in each of the cases in which we found problems.

Six Appointments

Involving Irregular or

Improper Actions

The nature of the irregular or improper actions in the six appointments is

summarized below and fully described in appendix I. We have redacted

personal identifiers of the appointees in appendix I for privacy protection

purposes.

• For three appointments, CPSC used improper candidate examination and

selection procedures. In two of those cases, it failed to follow veterans

preference rules. As a result, military veterans who were among the

candidates for the two positions were not provided the preference

consideration they were entitled to under veterans preference laws. In the

third case, CPSC failed to process the applications for appointment in

conformance with OPM instructions. As a result, CPSC made an invalid

appointment.

• Three of the six appointments were made with advanced rates of pay

based on the superior qualifications of the candidate, but we found no

written documentation to justify such rates. As required by federal

personnel regulations, agencies need to document the superior

qualifications that justify an advanced rate of pay.

• Two appointments were made using term appointment authority in which,

under justifiable circumstances, an agency can hire an individual for a

specific period of time, generally not exceeding 4 years. We questioned

whether the term appointment authority was properly used in these cases.

According to information in the employees’ personnel folders, the

Page 5 GAO/GGD-97-131 Personnel Practices
B-276748 

justification cited for the term appointments was to provide expertise on

special projects. However, the selecting official told us there were no

special projects in her office.

We brought our findings to OPM’s attention in December 1996 and asked

OPM, in its oversight capacity for ensuring agencies’ compliance with

personnel laws and regulations, whether it agreed with our assessment

and, if so, what corrective actions it would instruct CPSC to take. OPM

responded to us in March 1997 and, in general, agreed with our findings. In

regard to the two term appointments that did not appear to be justified,

OPM officials said that CPSC informed them that because the agency’s

funding level was uncertain, it decided to use term rather than permanent

appointments to meet staffing needs. The use of term appointments is

authorized under such conditions and therefore OPM did not consider these

appointments inappropriate. We agree that uncertain funding levels is a

bona fide justification for using term appointments, but the documentation

we reviewed did not indicate this rationale for these two term

appointments.

After receiving OPM’s response, we went back to CPSC and asked agency

officials the basis for providing OPM with a new justification for the term

appointments. CPSC officials said that the information in the two

appointees’ personnel folders citing special projects as the justification for

the term appointments was incorrect. CPSC officials told us that when the

two individuals were hired—in January 1995—the agency had already

received its fiscal year 1995 appropriation. But the agency felt

considerable uncertainty about the level of its 1996 funding due to the

possibility of changed political priorities in Congress. Officials said that

CPSC was concerned about committing permanent positions to the office in

question because an overcommitment of resources could require a later

reorganization. The officials acknowledged that they did not have any

documentation contemporaneous with the two appointments to support

the uncertain funding justification.

On one of the three superior qualification appointments, OPM determined

that the individual was eligible for the advanced pay rate based on his

previous highest salary and CPSC did not need to base the advanced pay

rate on superior qualifications. OPM instructed CPSC to correct the

personnel folder by deleting reference to superior qualifications.

OPM agreed with our remaining concerns and instructed CPSC to take

certain actions. For example, in the two instances in which CPSC did not

Page 6 GAO/GGD-97-131 Personnel Practices
B-276748 

follow veterans preference rules, CPSC was instructed to notify the

veterans that they will receive priority consideration for the next available

similar positions. OPM also instructed CPSC to fully document the superior

qualifications of and justify an advanced rate of pay for the two remaining

appointments made using the superior qualifications provision. CPSC

reported to OPM in April 1997 that it took the instructed corrective actions,

and OPM subsequently notified CPSC on May 28, 1997, that it was satisfied

with the actions taken. We verified that the actions were taken. OPM’s

position on each of the six cases is detailed in appendix II. We have

redacted personal identifiers of the appointees in appendix II for privacy

protection purposes.

Additional Appointments

Reviewed

CPSC, at our request, identified all appointments made between March 1994

and March 1997 in which advanced pay rates had been set. Excluding 3

advanced pay rate appointments that were part of our original review of

the 6 allegations, CPSC identified 20 cases. In 2 of the 20 cases, the

individuals had resigned from CPSC, their OPFs were not readily available

for review, and CPSC officials were unable to recall the details of the cases.

Of the remaining 18 cases, our review of the OPFs and discussions with

CPSC officials showed that the advanced rates of pay were based on the

superior qualifications of the individuals in 9 instances and on the highest

previous salaries of the individuals in 8 instances. In one instance, the

basis for the advanced rate of pay could not be determined from the

employee’s OPF.

Of the nine cases involving superior qualifications, five were justified at

the time of appointment by written documentation as required by

regulations. CPSC officials have since taken, or are currently taking, actions

to correct the other four cases. In the eight cases involving highest

previous salaries, supporting documentation was in the OPFs. In the

remaining case where the basis for the advanced rate could not be

determined, the CPSC personnel director told us that CPSC has since

determined that the employee’s pay was improperly set and that the

correction would be to reset the pay at a lower rate. However, because

this would result in a decreased salary level, and the error was made

through no fault of the employee, CPSC has requested a variance (or

exception) on this matter from OPM. According to the CPSC personnel

director, at the time this report was prepared OPM had not responded to

CPSC’s request.

Page 7 GAO/GGD-97-131 Personnel Practices
B-276748 

During a 2-week period beginning in September 1996, an OPM official—at

the request of CPSC—reviewed the appointments of all senior executives

and Schedule C employees employed at CPSC as of that time, as well as all

appointment and promotion actions taken on CPSC employees since

March 10, 1994. In total, the OPM official reviewed actions involving 167

employees and raised a variety of issues. Some were of an administrative

nature, such as filing employees’ security forms and fingerprint charts in

OPFs when such forms should be part of the employees’ security

investigation files. Other issues were of a more significant nature. For

example, OPM also identified, as we did, the four cases of advanced pay

rates based on superior qualifications where supporting documentation

did not exist. OPM also identified another case, not included in the scope of

our review, in which an employee had improperly received a quality step

increase (an increase in salary within the same pay grade based on quality

performance.) OPM determined that the increase was improper because it

was provided 8 weeks earlier than allowed by regulation. Federal

regulations provide that such an increase cannot be given an employee

who has received a quality step increase within the preceding 52 weeks.

CPSC waived the 8 weeks of overpayment and is correcting the OPF.

According to CPSC officials, all of the personnel problems we and OPM

identified were due to administrative errors or misunderstandings on the

part of the personnel office staff. The CPSC personnel director told us that

CPSC has taken numerous steps during our review to improve its personnel

operations and ensure compliance with all applicable federal laws and

regulations in the future. These include (1) providing additional training to

all personnel staff, (2) developing a checklist to ensure that personnel

actions are processed correctly, (3) developing written guidelines on

processing and documenting appointments with advanced rates of pay,

and (4) holding weekly staff meetings for personnel staff to discuss

current regulations.

CPSC Was Delegated

Examining Authority

In February 1996, OPM delegated examining authority to CPSC. Under

delegated examining authority, agencies typically recruit, accept

applications, score applicants on the basis of a review of education and

experience, maintain registers of qualified applicants, create certificates

listing the top-ranked candidates from the registers, and hire employees

from those certificates. Thus, CPSC now has greater responsibility for

personnel matters. While the problems CPSC had in the appointments we

reviewed occurred before the delegation of examining authority, the

Page 8 GAO/GGD-97-131 Personnel Practices
B-276748 

greater responsibility provided to CPSC by that authority makes it more

important now that OPM carefully watch over CPSC personnel activities.

According to OPM, it uses oversight reviews of agencies’ personnel

activities to gauge and ensure their compliance with merit system

principles, rules, and regulations. OPM annually selects and schedules

agencies for these reviews. An OPM official said OPM is planning to review

CPSC in 1998.

Conclusions Irregular and improper personnel appointments have been made at CPSC

over the past several years. CPSC has recognized the existence of such

problems and began to take actions during the course of our review to

correct previous improprieties and improve its personnel operations. Such

actions were both necessary and appropriate, as the integrity of the civil

service system rests on the consistent adherence to merit system

principles, rules, and regulations. Also, CPSC now has greater responsibility

for personnel actions under the examining authority delegated by OPM.

Because of this, and because of the past problems, we believe it important

for OPM to closely monitor CPSC’s personnel operations to ensure that the

agency is successful in its efforts to improve personnel operations.

Recommendation to

the Director of OPM

To help ensure that CPSC’s efforts to improve personnel operations are

successful and result in adherence to merit system principles, rules, and

regulations, we recommend that the Director of OPM include CPSC on OPM’s

next annual schedule of oversight reviews of agencies’ personnel actions.

CPSC should remain on OPM’s schedule until OPM is satisfied that CPSC is

maintaining personnel operations at a satisfactory level.

Agency Comments On June 17, 1997, the Executive Director of CPSC provided us written

comments on the draft (see app. III); and on June 19, 1997, the Deputy

Chief of Staff of OPM provided us oral comments on the draft. CPSC agreed

with our findings that errors in personnel processing occurred during the

period covered by our review and noted that the agency has worked to

implement the necessary corrective actions. OPM officials also agreed with

our findings. The Deputy Chief of Staff pointed out that OPM plans to

conduct an oversight review of CPSC personnel operations in 1998. He also

said that CPSC plans to contract with OPM for an independent audit of CPSC’s

use of delegated authority.

Page 9 GAO/GGD-97-131 Personnel Practices
B-276748 

As agreed with the Subcommittee, unless you publicly announce the

report’s contents earlier, we plan no further distribution of it until 15 days

after the date of this report. We will then send copies to the Ranking

Minority Member of the Subcommittee, the Chairman and Ranking

Minority Member of the Senate Committee on Governmental Affairs, the

Director of OPM, and the Chairman and other commissioners of CPSC. We

will also make copies available to others on request.

Please contact me at (202) 512-9039 if you or your staff have any questions.

Major contributors to this report were Richard W. Caradine, Assistant

Director; N. Scott Einhorn, Evaluator-in-Charge; and Stephen J. Kenealy,

Technical Advisor.

Sincerely yours,

Michael Brostek

Associate Director, Federal Management

and Workforce Issues

Page 10 GAO/GGD-97-131 Personnel Practices
Page 11 GAO/GGD-97-131 Personnel Practices
Contents

Letter 1

Appendix I 

December 5, 1996,

Referral Letter to the

Director, Office of

Personnel

Management, From

GAO

14

Appendix II 

March 3, 1997,

Response From the

Director, Office of

Personnel

Management, to

GAO’S Referral Letter

33

Appendix III 

Comments From the

U.S. Consumer

Product Safety

Commission

49

Abbreviations

CPSC Consumer Product Safety Commission

FTE full-time equivalent

IRS Internal Revenue Service

OPM Office of Personnel Management

OPF Official Personnel Folder

PBGC Pension Benefit Guaranty Corporation

Page 12 GAO/GGD-97-131 Personnel Practices
Page 13 GAO/GGD-97-131 Personnel Practices
Appendix I 

December 5, 1996, Referral Letter to the

Director, Office of Personnel Management,

From GAO

Page 14 GAO/GGD-97-131 Personnel Practices
Appendix I 

December 5, 1996, Referral Letter to the

Director, Office of Personnel Management,

From GAO

Note: Personal identifiers

have been redacted.

Page 15 GAO/GGD-97-131 Personnel Practices
Appendix I 

December 5, 1996, Referral Letter to the

Director, Office of Personnel Management,

From GAO

Page 16 GAO/GGD-97-131 Personnel Practices
Appendix I 

December 5, 1996, Referral Letter to the

Director, Office of Personnel Management,

From GAO

Page 17 GAO/GGD-97-131 Personnel Practices
Appendix I 

December 5, 1996, Referral Letter to the

Director, Office of Personnel Management,

From GAO

Page 18 GAO/GGD-97-131 Personnel Practices
Appendix I 

December 5, 1996, Referral Letter to the

Director, Office of Personnel Management,

From GAO

Page 19 GAO/GGD-97-131 Personnel Practices
Appendix I 

December 5, 1996, Referral Letter to the

Director, Office of Personnel Management,

From GAO

Page 20 GAO/GGD-97-131 Personnel Practices
Appendix I 

December 5, 1996, Referral Letter to the

Director, Office of Personnel Management,

From GAO

Page 21 GAO/GGD-97-131 Personnel Practices
Appendix I 

December 5, 1996, Referral Letter to the

Director, Office of Personnel Management,

From GAO

Page 22 GAO/GGD-97-131 Personnel Practices
Appendix I 

December 5, 1996, Referral Letter to the

Director, Office of Personnel Management,

From GAO

Page 23 GAO/GGD-97-131 Personnel Practices
Appendix I 

December 5, 1996, Referral Letter to the

Director, Office of Personnel Management,

From GAO

Page 24 GAO/GGD-97-131 Personnel Practices
Appendix I 

December 5, 1996, Referral Letter to the

Director, Office of Personnel Management,

From GAO

Page 25 GAO/GGD-97-131 Personnel Practices
Appendix I 

December 5, 1996, Referral Letter to the

Director, Office of Personnel Management,

From GAO

Page 26 GAO/GGD-97-131 Personnel Practices
Appendix I 

December 5, 1996, Referral Letter to the

Director, Office of Personnel Management,

From GAO

Page 27 GAO/GGD-97-131 Personnel Practices
Appendix I 

December 5, 1996, Referral Letter to the

Director, Office of Personnel Management,

From GAO

Page 28 GAO/GGD-97-131 Personnel Practices
Appendix I 

December 5, 1996, Referral Letter to the

Director, Office of Personnel Management,

From GAO

Page 29 GAO/GGD-97-131 Personnel Practices
Appendix I 

December 5, 1996, Referral Letter to the

Director, Office of Personnel Management,

From GAO

Page 30 GAO/GGD-97-131 Personnel Practices
Appendix I 

December 5, 1996, Referral Letter to the

Director, Office of Personnel Management,

From GAO

Page 31 GAO/GGD-97-131 Personnel Practices
Appendix I 

December 5, 1996, Referral Letter to the

Director, Office of Personnel Management,

From GAO

Page 32 GAO/GGD-97-131 Personnel Practices
Appendix II 

March 3, 1997, Response From the Director,

Office of Personnel Management, to GAO’S

Referral Letter

Page 33 GAO/GGD-97-131 Personnel Practices
Appendix II 

March 3, 1997, Response From the Director,

Office of Personnel Management, to GAO’S

Referral Letter

Note: Personal identifiers

have been redacted.

Page 34 GAO/GGD-97-131 Personnel Practices
Appendix II 

March 3, 1997, Response From the Director,

Office of Personnel Management, to GAO’S

Referral Letter

Page 35 GAO/GGD-97-131 Personnel Practices
Appendix II 

March 3, 1997, Response From the Director,

Office of Personnel Management, to GAO’S

Referral Letter

Page 36 GAO/GGD-97-131 Personnel Practices
Appendix II 

March 3, 1997, Response From the Director,

Office of Personnel Management, to GAO’S

Referral Letter

Page 37 GAO/GGD-97-131 Personnel Practices
Appendix II 

March 3, 1997, Response From the Director,

Office of Personnel Management, to GAO’S

Referral Letter

Page 38 GAO/GGD-97-131 Personnel Practices
Appendix II 

March 3, 1997, Response From the Director,

Office of Personnel Management, to GAO’S

Referral Letter

Page 39 GAO/GGD-97-131 Personnel Practices
Appendix II 

March 3, 1997, Response From the Director,

Office of Personnel Management, to GAO’S

Referral Letter

Page 40 GAO/GGD-97-131 Personnel Practices
Appendix II 

March 3, 1997, Response From the Director,

Office of Personnel Management, to GAO’S

Referral Letter

Page 41 GAO/GGD-97-131 Personnel Practices
Appendix II 

March 3, 1997, Response From the Director,

Office of Personnel Management, to GAO’S

Referral Letter

Page 42 GAO/GGD-97-131 Personnel Practices
Appendix II 

March 3, 1997, Response From the Director,

Office of Personnel Management, to GAO’S

Referral Letter

Page 43 GAO/GGD-97-131 Personnel Practices
Appendix II 

March 3, 1997, Response From the Director,

Office of Personnel Management, to GAO’S

Referral Letter

Page 44 GAO/GGD-97-131 Personnel Practices
Appendix II 

March 3, 1997, Response From the Director,

Office of Personnel Management, to GAO’S

Referral Letter

Page 45 GAO/GGD-97-131 Personnel Practices
Appendix II 

March 3, 1997, Response From the Director,

Office of Personnel Management, to GAO’S

Referral Letter

Page 46 GAO/GGD-97-131 Personnel Practices
Appendix II 

March 3, 1997, Response From the Director,

Office of Personnel Management, to GAO’S

Referral Letter

Page 47 GAO/GGD-97-131 Personnel Practices
Appendix II 

March 3, 1997, Response From the Director,

Office of Personnel Management, to GAO’S

Referral Letter

Page 48 GAO/GGD-97-131 Personnel Practices
Appendix III 

Comments From the U.S. Consumer Product

Safety Commission

Page 49 GAO/GGD-97-131 Personnel Practices
Appendix III 

Comments From the U.S. Consumer Product

Safety Commission

(410131) Page 50 GAO/GGD-97-131 Personnel Practices
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