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CSB Needs to Improve Its 

Acquisition Approvals and 

Other Processes to Ensure 

Best Value for Taxpayers

Report No. 15-P-0245 July 31, 2015

U.S. ENVIRONMENTAL PROTECTION AGENCY

OFFICE OF INSPECTOR GENERAL

Hotline Report: U.S. Chemical Safety Board 
Report Contributors: Andrés Calderón

Michael Davis

Anthony Grear

Marcia Hirt-Reigeluth

Cara Lindsey

Gloria Taylor-Upshaw

Abbreviations

CO Contracting Officer

CPARS Contractor Performance Assessment Reporting System

CSB U.S. Chemical Safety and Hazard Investigation Board

FAR Federal Acquisition Regulation

OIG Office of Inspector General

OMB Office of Management and Budget

PPIRS Past Performance Information Retrieval System

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 15-P-0245

July 31, 2015

Why We Did This Review

The Office of Inspector 

General (OIG) of the 

U.S. Environmental Protection 

Agency received a hotline 

complaint about a 

U.S. Chemical Safety and 

Hazard Investigation Board 

(CSB) contract awarded for 

about $1 million. In response to 

the complaint, the OIG initiated 

an audit to determine whether 

CSB effectively manages its 

contracts. The Inspector 

General for the U.S. 

Environmental Protection 

Agency is also the Inspector 

General for CSB. 

This report addresses the 

following CSB goal:

 Preserve the public trust by 

maintaining and improving 

organizational excellence.

Send all inquiries to our public

affairs office at (202) 566-2391

or visit www.epa.gov/oig.

The full report is at:

www.epa.gov/oig/reports/2015/ 

20150731-15-P-0245.pdf

 

CSB Needs to Improve Its Acquisition Approvals and 

Other Processes to Ensure Best Value for Taxpayers

 What We Found

CSB did not have in its contract files the 

proper approvals to allocate funds for 

13 contracts and interagency agreements 

totaling over $1.9 million. 

In October 2014, CSB issued instructions

for managing acquisitions that were 

inconsistent with then-existing board orders that governed acquisitions. In 

January 2015, the Board rescinded those board orders. CSB does not have a 

method that controls or explains the updating of policies and procedures or the 

distinction between board orders and management directives.

CSB has not followed its internal controls and has not implemented the OIG’s

February 2011 audit recommendation to develop and implement a management 

control plan. By not adhering to its internal controls, CSB places its acquisitions 

process at risk. In addition, without a method to implement controls, CSB is at 

risk for ineffective and inefficient operations.

Further, CSB did not perform market research actions for two contracts totaling 

over $380,000, and did not monitor or establish plans to monitor the quality of 

contract work performed through the use of quality assurance surveillance plans. 

Lastly, CSB did not know the extent to which contractor past performance 

information was used. 

 Recommendations and Planned Agency Corrective Actions

We recommend that the CSB Board communicate to staff the requirement to 

follow acquisition policies and procedures. Further, we recommend that the 

Board update CSB’s management control plan to set forth a method for updating 

policies and procedures and explain the distinction between board orders and 

management instructions. In addition, we recommend that the Board establish

internal controls to document market research actions, monitoring quality for

contracts when awarded, and internal controls to ensure contractor performance 

evaluations are properly documented.

CSB stated it plans to fully address our recommendations and provided 

corrective actions with milestone dates.

U.S. Environmental Protection Agency

Office of Inspector General

At a Glance

CSB’s acquisition process is at 

risk and may have ineffective 

operations without a strategy 

to implement controls. Further, 

CSB has limited evidence it 

contracted at the best value.
July 31, 2015

The Honorable Rick Engler

The Honorable Manuel Ehrlich Jr.

Board Members

U.S. Chemical Safety and Hazard Investigation Board

2175 K Street, NW, Suite 400

Washington, D.C. 20037-1809

Dear Board Members:

This is our report on the audit of the U.S. Chemical Safety and Hazard Investigation Board’s (CSB’s)

acquisition process conducted by the Office of Inspector General (OIG) of the U.S. Environmental 

Protection Agency. This report contains findings that describe the problems the OIG has identified and 

corrective actions the OIG recommends. This report represents the opinion of the OIG and does not 

necessarily represent the final CSB position. CSB managers will make the final determinations on 

matters in this report.

Because you concurred with our recommendations and provided planned corrective actions that meet the 

intent of the recommendations, along with completion dates, you are not required to provide a written 

response to this report. However, if you submit a response, it will be posted on the OIG’s public website, 

along with our memorandum commenting on your response. Your response should be provided as an 

Adobe PDF file that complies with the accessibility requirements of Section 508 of the Rehabilitation 

Act of 1973, as amended. The final response should not contain data that you do not want to be released 

to the public; if your response contains such data, you should identify the data for redaction or removal 

along with corresponding justification. 

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

Sincerely,

Arthur A. Elkins Jr.

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C. 20460

THE INSPECTOR GENERAL
CSB Needs to Improve Its Acquisition Approvals and 15-P-0245

Other Processes to Ensure Best Value for Taxpayers

Table of Contents

Chapters

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

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

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

Scope and Methodology ............................................................................ 2

Prior Audit Coverage.................................................................................. 3

2 CSB Acquisitions Did Not Have Proper Approvals and CSB

Needs a Strategy for Internal Controls............................................................ 5

OMB Guidance Addresses the Need for Internal Control ........................... 5

CSB Rescinded Board Orders That Governed the 

 Acquisition Process............................................................................. 5

CSB’s New Directive Realigned the Acquisition Process,

 But Several Acquisitions Were Not Properly Approved ....................... 7

Conclusion................................................................................................. 8

Recommendations..................................................................................... 8

CSB Comments and OIG Evaluation ......................................................... 9

3 CSB Did Not Document Market Research, Contract Surveillance 

or Past Performance......................................................................................... 10

FAR Addresses Documentation................................................................. 10

CSB Needs to Document Its Actions in Its Acquisition Files....................... 11

CSB Aware of Need to Record Actions in Acquisition Files........................ 11

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

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

CSB Comments and OIG Evaluation ......................................................... 12

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

Appendices

A CSB Response to Draft Report........................................................................ 14

B Distribution ....................................................................................................... 17
15-P-0245 1

Chapter 1

Introduction

Purpose

The U.S. Environmental Protection Agency’s Office of Inspector General 

(OIG)—which is also the OIG for the U.S. Chemical Safety and Hazard 

Investigation Board (CSB)—received a hotline complaint about a CSB contract 

awarded for about $1 million. In response to the complaint, we initiated an audit 

to determine whether CSB effectively manages its contracts.

Background

Authorized by the Clean Air Act Amendments of 1990 (42 U.S.C. Section 

7412(r)(6)), CSB began operating in 1998 as an independent federal government 

organization. CSB’s headquarters is in Washington, D.C., with an investigation 

office in Denver, Colorado. CSB’s mission is to enhance the health and safety of the 

public, workers and environment by determining the root causes of accidental 

chemical releases, and use those findings to promote preventive actions by the 

private and public sectors. The agency does not issue fines or citations; rather, it

makes recommendations to plants, industry organizations, labor groups, and 

regulatory agencies such as the Occupational Safety and Health Administration and 

U.S. Environmental Protection Agency. 

The President appoints, and the Senate confirms, CSB’s Board members. The 

Board Chairperson serves as the Chief Executive Officer and is responsible for 

agency administration, while the full Board is responsible for major budgeting 

decisions, strategic planning and direction, general agency oversight, and 

approval of investigation reports and studies. Although the CSB Board is 

supposed to be composed of five members, including the Chairperson, during our

audit the CSB Board has changed in the number of members. As of July 2015, the

Board consisted of two members and no Chairperson.

CSB contracting officers (COs) process contracts and purchase orders. COs

formulate performance work statements and cost estimates, and send them to the 

CSB Managing Director for approval. Under the current process, the Managing 

Director approves interagency agreements valued at less than $50,000 and the 

Chairperson approves agreements greater than $50,000.

Once the performance work statement and cost estimate have been approved, 

acquisition information is entered into a procurement automated requisition 

system so that CSB can track and manage the lifecycle of the award. 
15-P-0245 2

After the CSB Finance Director approves the requisition, the CO develops the

acquisition plan and performs the market research part of the plan. CSB stated 

that as part of its market research process, COs review small business vendors; the 

“directory.gov” website; and the Federal Procurement Data System, which is a 

central registry for the federal government that goes back 5 years.

Upon completion of the acquisition plan, all the sources for the award (small 

business, women owned, disabled veteran, etc.) are defined and posted in a

General Services Administration online quote tool. After CSB receives quotes 

from vendors, the CO verifies that those vendors are not on the suspension or

debarment lists. COs also check the e-library to make sure the vendor has not 

improperly classified itself (small business, women owned, disabled veteran, etc.) 

to gain a federal contract.

Scope and Methodology

We conducted this audit from February 2014 to May 2015 in accordance with 

generally accepted government auditing standards issued by the Comptroller 

General of the United States. Those standards require that we plan and perform 

the audit to obtain sufficient, appropriate evidence to provide a reasonable basis 

for our findings and conclusions based on our objective. We believe that the 

evidence obtained provides a reasonable basis for our findings and conclusions 

based on our audit objective.

At the start of our audit, CSB provided an Excel spreadsheet showing 278 

acquisitions that included interagency agreements, contracts and purchase orders

for the period of October 1, 2008, to September 30, 2013. We judgmentally 

selected a sample of seven contracts of the 278 acquisitions listed on the 

spreadsheet based on dollar amount. 

We visited CSB’s headquarters in Washington, D.C., the week of March 31 

through April 4, 2014. During our site visit, CSB provided access to 

150 acquisition files as of March 31, 2014. We audited acquisition files greater 

than $50,000 for required board order approvals. 

We also held interviews and discussions with CSB staff that included COs and 

their representatives. We performed a walk-through of the contracting process.

We read CSB’s acquisition-related Board Orders 024, 027 and 028; the Federal 

Acquisition Regulation (FAR); and the Office of Management and Budget (OMB)

guidance that address internal controls over CSB’s acquisition processes and 

federal contracting requirements.
15-P-0245 3

Audit Delays 

We had notified CSB of the start of this project in June 2013, but CSB proposed 

that the review start at the end of the fiscal year due to staff working on several 

high-priority projects. The Inspector General granted an extension to September 

2013 and notified CSB that the project would resume in December 2013. In 

November 2013, prior to the start of the project, CSB proposed that the audit start 

the first week of February 2014 due to work on other audits and conflicts with 

vacations and competing priorities. The Inspector General granted a second 

extension, and we resumed this project in February 2014.

Prior Audit Coverage 

On October 29, 2014, we issued our Early Warning Report: Not Following 

Internal Controls Put Acquisitions at Risk1(Report No. 15-P-0007), to convey 

significant, time-critical issues to CSB management before the audit team 

completed this full report. We believed that CSB did not follow its then applicable

internal controls requiring Board approval for acquisitions over $50,000, and did 

not document its market research and contract surveillance actions. CSB provided 

written comments for our consideration, and we posted those comments (along 

with the early warning report itself) to our website.

2

On February 15, 2011, we issued the report Chemical Safety and Hazard 

Investigation Board Did Not Take Effective Corrective Actions on Prior Audit 

Recommendations3(Report No. 11-P-0115). In Recommendation 1, the report 

identified the need to develop and implement a management control plan that 

documents and addresses the five internal control standards in accordance with 

OMB Circular A-123 and the U.S. Government Accountability Office’s 

Standards for Internal Controls in the Federal Government. Specifically, in 

sub-recommendation b, the report recommended procedures for conducting 

periodic internal control reviews and properly documenting those reviews, 

including verifying and ensuring that audit recommendations are resolved 

promptly. CSB indicated its intention to develop a management control plan as an 

initiative in its fiscal year 2011 action plan. CSB expects completion by the end of 

the fiscal year.

In Recommendation 6, sub-recommendations c and e, the report identified prior 

recommendations made by three OIGs and the U.S. Government Accountability 

Office from fiscal years 2000 through 2008 that had not been implemented. 

Specifically, we recommended that CSB update: 

 

1 http://www.epa.gov/oig/reports/2014/20141029-15-P-0007.pdf. 

2 http://www.epa.gov/oig/reports/2014/20141029-15-P-0007_CSB Response to OIG Discussion Document.pdf and 

http://www.epa.gov/oig/reports/2014/20141029-15-P-0007_Moss Opinion.pdf. 

3 http://www.epa.gov/oig/reports/2011/20110215-11-P-0115.pdf. 
15-P-0245 4

c. Board Order 027, “Roles, Responsibilities, and Standards of Conduct in 

Procurement Activities,” to reflect current procurement practices and 

processes to ensure consistency in the procurement.

e. Board Order 028, “Executive and Administrative Functions of the Board,” 

to document the role and responsibility of the Managing Director position. 

CSB rescinded the board orders in January 2015. However, CSB stated that it is 

currently revisiting Board Orders 024, 027 and 028, and is committed to

updating and re-issuing these orders.
15-P-0245 5

Chapter 2

CSB Acquisitions Did Not Have Proper Approvals

and CSB Needs a Strategy for Internal Controls

CSB did not have in its contract files the proper approvals to allocate funds for 

13 contracts totaling over $1.9 million. In October 2014, CSB issued instructions 

for managing acquisitions that were inconsistent with then-existing board orders 

that governed acquisitions. In January 2015, the Board rescinded those Board 

Orders. CSB does not have a method that controls or explains the updating of 

policies and procedures or the distinction between board orders and management 

directives. The management directive requires the Chairperson and/or Board to 

approve funds for contracts and requests that exceed $50,000. OMB Circular 

A-123, Revised, states that to implement effective internal controls, management 

should have an organized strategy with well-defined documentation processes. 

CSB has not followed its internal controls nor implemented our February 2011 

audit recommendation to develop and implement a management control plan. 

Consequently, CSB places its acquisition process, including the efficiency and 

effectiveness of operations, at risk.

OMB Guidance Addresses the Need for Internal Control

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

focuses on management’s responsibility for internal control in federal agencies. It 

defines internal control as organization, policies and procedures that help programs

and financial managers achieve results and safeguard the integrity of their programs. 

To implement effective internal control, OMB Circular A-123, Revised, states:

[M]anagement should have a clear, organized strategy with 

well-defined documentation processes that contain an audit trail, 

verifiable results, and specify document retention periods so that 

someone not connected with the procedures can understand the 

assessment process.

It also stresses the need for management to clearly “define areas of authority and 

responsibility; appropriately delegate the authority and responsibility throughout 

the agency....” 

CSB Rescinded Board Orders That Governed the Acquisition Process

Our initial audit found that CSB had three board orders to govern procurement 

activities (Board Orders 024, 027 and 028) that it did not follow. In October 2014, 

CSB issued a management directive, CSB Management Directive #1, CSB 

Acquisition Policy and Procedures, that set forth policies and procedures 

applicable to contracting activities. The directive outlines roles and 
15-P-0245 6

responsibilities for review and approval of funding for requests that result in an 

order or contract. At a public meeting in January 2015, CSB issued Board Order 

2015-01, Streamlining of Chemical Safety Board System of Board Order, which 

supported the Chairperson’s issuance of the management directive. CSB did not 

explain the distinction between the use of board orders and management 

directives within the agency.

Regarding the board orders:

 Board Order 024 was CSB’s policy and procedures for the acquisition of 

supplies and services. It was about 15 years old (effective December 27, 

1999) and reflected the processes in place when the then Bureau of Public 

Debt4 managed CSB’s contracts under an interagency agreement. Also, 

Board Order 024 stated that an internal review of the order should be done 

every 2 years, but CSB had not yet performed an internal review. 

 Board Order 027 (effective June 4, 2002) set forth the respective roles and 

responsibilities of key participants in CSB procurement activities and 

established standards for the conduct of the Chairperson, Board members, 

Chief Operating Officer, and staff in carrying out their appropriate roles. 

Section 6a stated that the Board’s role in the procurement activities of 

CSB consists of approving the allocation of funds for those contracts, 

interagency transfers or other expenditures exceeding $50,000.

 Board Order 028 (effective August 5, 2002, and amended in 2006) 

established the manner in which the Board shall exercise its executive and 

administrative functions through the position of the Chairperson. 

Section 6b (1) stated the authority to control the use and expenditure of 

funds, including the power to authorize and execute contracts and 

interagency transfers in an amount not to exceed $50,000. Section 8f 

stated that items that must be approved by the Board include contracts, 

interagency transfers or other expenditures exceeding $50,000.

CSB rescinded the three orders through a Board vote that implemented Board 

Order 2015-01 at a public meeting. Board Order 2015-01 states that “[t]he 

Chairperson is authorized to approve and implement Management Directives 

needed to support the administrative requirements of the CSB, as a Federal agency, 

in accordance with applicable statutes, regulations or Executive Orders.”

CSB management told the OIG that Management Directive #1 replaces Board 

Orders 024 and 027 regarding CSB procurement functions and replaces those 

parts of Board Order 028 that purported to limit the Chair’s authority over 

contracting and ordering. The directive did not state it is a replacement to any 

board orders. Also, there is no mention of CSB’s strategy for updating policies 

 

4 The Bureau of Public Debt was changed to the Bureau of the Fiscal Service in 2012.
15-P-0245 7

and procedures or the distinction between the use of board orders and 

management directives. 

CSB’s New Directive Realigned the Acquisition Process,

But Several Acquisitions Were Not Properly Approved

The CSB Management Directive #1 changed the approval roles for requests and 

contracts that exceeded $50,000 from those previously identified in the three 

rescinded board orders. Regardless of whether the board order or management 

directive controlled the acquisition process, CSB did not have required 

documentation in the contract files to support the proper approvals.

Management Directive #1 notes the following roles and responsibilities for the 

approval of funding and requests that result in an order or contract:

[Managing Director:] Review and approval for obligation of 

funds, all requests that result in an order or contract up to $50,000.

[Chairperson:] Review and approval for obligation of funds, all 

administrative requests that result in an order or contract exceeding 

$50,000.

[Board:] Review and approve mission-related requests that result 

in an order or contract exceeding the Simplified Acquisition 

Threshold [$150,000].

CSB did not have in its contracts files the proper approvals to allocate funds for 

13 contracts and interagency agreements totaling over $1.9 million. We requested 

that CSB provide a list of all awarded contracts for the period of October 1, 2008, 

to September 30, 2013. CSB provided an Excel spreadsheet showing 278 

acquisitions that included interagency agreements, contracts and purchase orders.

Our audit of this spreadsheet disclosed seven contracts and interagency 

agreements over $50,000, totaling over $1 million, that did not have the proper

approvals. We identified a contract for Internet services, totaling over $300,000

that exceeded the $150,000 simplified acquisition threshold, which was approved 

by the Managing Director. There was no documentation in the file denoting the

Chairperson or Board approval as required by CSB’s prior or current policies and 

procedures. During our site visit to CSB, we obtained access to 150 acquisition 

files and identified six additional contracts and interagency agreements totaling 

over $800,000 for which CSB did not have the proper approvals. There was a 

contract estimated at over $250,000 and an interagency agreement that totaled 

over $300,000 that were approved by the Managing Director and not the

Chairperson or Board as required.

We previously reported our concerns regarding CSB not following its internal 

controls in our aforementioned Early Warning Report: Not Following Internal 

Controls Put Acquisitions at Risk.
15-P-0245 8

Conclusion

CSB updated its acquisition policies and procedures with Management Directive 

#1, but did not rescind the three pertinent board orders governing procurement 

activities until January 2015. CSB was not following its internal controls for 

acquisition approvals, and we found 13 contracts and interagency agreements 

totaling over $1.9 million that did not have in the contract files the proper 

approvals in accordance with the prior or current policies and procedures. Further, 

CSB did not have a strategy for updating policies and procedures or defining the 

distinction between directives and board orders. 

As recommended in our aforementioned report, Chemical Safety and Hazard 

Investigation Board Did Not Take Effective Corrective Actions on Prior Audit 

Recommendations, CSB should develop and implement a management control plan 

that documents and addresses the five internal control standards in accordance with 

OMB Circular A-123 and the U.S. Government Accountability Office’s 

Standards for Internal Controls in the Federal Government. We believe that a 

management control plan is needed to schedule future updates to policies and 

procedures as well as document an overall agency strategy for its board orders and 

management directives. If implemented, this recommendation would help lower 

CSB’s risk for ineffective and inefficient operations.

CSB stated that at a public meeting held on May 6, 2015, it rescinded 

much of Board Order 2015-01, with the exception of Board Orders 024, 

027 and 028, in an effort to normalize agency operations. CSB stated it is

currently revisiting Board Orders 024, 027 and 028, and is committed to

updating and re-issuing these orders. In addition, CSB stated it has

completed a draft Management Accountability Control Plan and the plan

is currently under review. CSB noted that a target date of the end of the

fiscal year is set to ensure the proper Board review and acceptance. CSB 

stated that it remains committed to formally approving the plan.

Recommendations

We recommend that the U.S. Chemical Safety and Hazard Investigation Board:

1. Communicate to staff the requirement to follow acquisition policies and 

procedures to ensure that contracts and requests have the proper approvals.

2. Update CSB’s management control plan to set forth a method for updating 

policies and procedures and define the distinction between board orders 

and management directives.
15-P-0245 9

CSB Comments and OIG Evaluation

We received comments from CSB that stated it plans to fully address each

recommendation. Appendix A contains CSB’s full response to our draft 

report.

We agree with CSB’s response to our recommendations. CSB provided planned 

corrective actions and estimated completion dates that meet the intent of the 

recommendations. We consider all recommendations resolved and require no final 

response to this report. Recommendations will remain open until CSB completes

the corrective actions.
15-P-0245 10

Chapter 3

CSB Did Not Document Market Research, 

Contract Surveillance or Past Performance

CSB did not perform market research actions for two contracts totaling over 

$380,000. Further, CSB did not monitor or establish plans to monitor the quality 

of contract work performed through the use of quality assurance surveillance 

plans for all seven contracts reviewed totaling over $1.4 million. Also, CSB did 

not create formal quality assurance surveillance plans. In addition, CSB did not 

know the extent that past performance information was documented in the 

Contractor Performance Assessment Reporting System (CPARS). The FAR 

emphasizes the importance of market research, contract surveillance and 

documenting past performance. CSB stated it conducted sufficient market 

research and contract surveillance but acknowledged it could do a better job of 

documenting its efforts in contract files. Also, CSB stated that COs only recently 

acquired access to CPARS. Without documentation, CSB has limited evidence

that it has awarded contracts that are the best value for the government.

FAR Addresses Documentation

The FAR notes that market research, contract surveillance and past performance 

are important parts of the acquisition process. 

FAR Part 10, Market Research, Section 10.001, states that agencies must conduct 

market research appropriate for the circumstances before developing requirements 

and soliciting offers. 

FAR Subpart 46.103, Contracting Office Responsibilities, calls on contracting 

offices to establish specifications for inspection, testing and other contract quality 

requirements essential to ensure the integrity of the supplies or services. 

FAR Subpart 46.104, Contract Administration Office Responsibilities, states COs

should, “[m]aintain, as part of the performance records of the contract, suitable 

records reflecting—(1) The nature of Government contract quality assurance 

actions, including, when appropriate, the number of observations made and the 

number and type of defects....” 

FAR Subpart 42.15, Contractor Performance Information, 42.1501(b), General,

states that agencies shall monitor their compliance with past performance 

evaluation requirements and use the CPARS and Past Performance Information 

Retrieval System (PPIRS) metric tools to measure the quality and timely reporting 

of past performance information.
15-P-0245 11

FAR 42.1502(a), Policy, and FAR 42.1503(f) and (g), Procedures, explain that 

past performance evaluations should be prepared at least annually and at the time 

a contract or order is completed. Agencies prepare and submit all past 

performance evaluations electronically in CPARS. These evaluations are 

automatically transmitted to PPIRS. The information in PPIRS is used by 

agencies for source-selection purposes. Agencies shall use past performance 

information in PPIRS that is within 3 years of the completion of performance of 

the evaluated contract or order.

CSB Needs to Document Its Actions in Its Acquisition Files

For the seven sampled contracts, CSB did not perform market research actions for 

two of those contracts, totaling over $380,000. CSB did not perform quality 

assurance surveillance actions for all seven sampled contracts that totaled over 

$1.4 million. CSB stated it performed market research actions, but the research 

information was not identified as such nor documented within the contracting 

office files. CSB did not create formal quality assurance surveillance plans; 

rather, it stated CSB relied on informal surveillance of contractor actions. 

Although CSB began awarding procurements during fiscal year 2012, it did not

know whether contractor performance was recorded in CPARS.

CSB Aware of Need to Record Actions in Acquisition Files

CSB’s COs acknowledged that CSB could do a better job recording market 

research actions in the acquisition files. One CO stated that he looks at many 

documents but does not record the activity in the contract files. The other CO 

stated that most of the market research CSB performed was conducted orally.

CSB stated that, historically, COs relied on their representatives to help with 

quality assurance actions. CSB stated that recording quality assurance actions has 

been an informal process in which the CO checked on the contractor’s fulfillment 

of the contract requirements. CSB agreed that a formal process is needed to 

document the surveillance actions. 

CSB COs stated they are familiar with data entered into CPARS so that it can be 

viewed in PPIRS. A CO stated it has been difficult to connect with CPARS and 

the CO does not know the extent that contracting officer representatives were 

using CPARS/PPIRS when conducting their market research. 

We believe that CSB should record actions performed during the acquisition 

process in its acquisition files and record contractor performance in CPARS to 

ensure CSB has evidence of following federal procedures. Further, documenting 

contractor performance provides information that other agencies can review prior 

to acquiring services from that contractor.
15-P-0245 12

Conclusion

CSB does not have market research and quality assurance evidence in its contract 

files and CPARS to document that it has awarded contracts that are the best value 

for the government. By not establishing and performing quality assurance 

surveillance plans and actions, CSB acquisition files show limited evidence that 

CSB received sufficient value for the goods and services for which it paid over 

$1.4 million.

As result of our early warning report. CSB stated it registered all contracts over 

$150,000 in the CPARS database, developed forms for documenting market 

research and quality assurance, and stressed quality assurance surveillance in its 

contracting officer representative training held in June 2014.

Recommendations

We recommend that the U.S. Chemical Safety and Hazard Investigation Board:

3. Establish internal controls to document market research actions—

including emails, Internet searches and telephone conversations—in the 

acquisition files.

4. Establish quality assurance surveillance plans for contracts when awarded,

and include documentation of reviews or analyses in the acquisition files.

5. Establish internal controls to ensure performance evaluations of 

contractors are documented in the contract files and recorded in CPARS.

CSB Comments and OIG Evaluation

We received comments from CSB that stated it plans to address fully each

recommendation. Appendix A contains CSB’s full response to our draft 

report.

We agree with CSB’s response to our recommendations. CSB provided planned 

corrective actions and estimated completion dates that meet the intent of the 

recommendations. We consider all recommendations resolved and require no 

final response to this report. Recommendations will remain open until CSB 

completes the corrective actions.
15-P-0245 13

Status of Recommendations and 

Potential Monetary Benefits

RECOMMENDATIONS

POTENTIAL MONETARY 

BENEFITS (in $000s)

Rec. 

No.

Page 

No. Subject Status1 Action Official

Planned 

Completion 

Date

Claimed 

Amount

Agreed-To 

Amount

1 8 Communicate to staff the requirement to follow 

acquisition policies and procedures to ensure that 

contracts and requests have the proper approvals.

O U.S. Chemical Safety and 

Hazard Investigation Board

9/30/15

2 8 Update CSB’s management control plan to set forth 

a method for updating policies and procedures and 

define the distinction between board orders and 

management directives.

O U.S. Chemical Safety and 

Hazard Investigation Board

9/30/15

3 12 Establish internal controls to document market 

research actions—including emails, Internet 

searches and telephone conversations—in the 

acquisition files.

O U.S. Chemical Safety and 

Hazard Investigation Board

8/1/15

4 12 Establish quality assurance surveillance plans for 

contracts when awarded, and include documentation 

of reviews or analyses in the acquisition files.

O U.S. Chemical Safety and 

Hazard Investigation Board

8/1/15

5 12 Establish internal controls to ensure performance 

evaluations of contractors are documented in the 

contract files and recorded in CPARS.

O U.S. Chemical Safety and 

Hazard Investigation Board

8/1/15

1 O = Recommendation is open with agreed-to corrective actions pending. 

C = Recommendation is closed with all agreed-to actions completed. 

U = Recommendation is unresolved with resolution efforts in progress.
15-P-0245 14

Appendix A

CSB Response to Draft Report
15-P-0245 15
15-P-0245 16
15-P-0245 17

Appendix B

Distribution

Board Members, U.S. Chemical Safety and Hazard Investigation Board

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

 Investigation Board

Communications Manager, U.S. Chemical Safety and Hazard Investigation Board