Office of Inspector General

Audit Report

INFORMATION TECHNOLOGY

Unreliable Data Affects Usability 

of DOCKET Information

Report Number 2002-P-00004

January 18, 2002
Inspector General Division

 Conducting the Audit

Information Technology Audits Staff,

 Washington, DC

Regions Covered All

Program Office Involved Office of Enforcement and Compliance Assurance

Audit Team Members Ed Shields

Chuck Dade

John Ewan

Rudolph Brevard

Teresa Richardson

Judy Tsai

David Cofer

Abbreviations

AO Administrative Order

CCDS Case Conclusion Data Sheet

CDETS Consent Decree Tracking System

DOCKET EPA’s National Enforcement Docket System

EPA United States Environmental Protection Agency

GAO United States General Accounting Office

GPRA Government Performance and Results Act

ICIS Integrated Compliance Information System

IDEA Interactive Data Extraction and Analysis Software

IG Inspector General

OECA Office of Enforcement and Compliance Assurance

OIG Office of Inspector General

Regions Ten Regional Offices, Headquarters’ Mobile Source Enforcement Branch, and

Headquarters’ Toxics and Pesticides Enforcement Division

SEP Supplemental Environmental Project

We appreciate the cooperation afforded us during the course of this audit by the Regions

and OECA. We have no objections to the further release of this report to the public. Should you

or your staff have any questions regarding this report, please contact Ed Shields, Audit Manager,

Information Technology Audits Staff, at (202) 260-3656.

Attachment
Report No. 2002-P-00004

EXECUTIVE SUMMARY

INTRODUCTION The National Enforcement Docket System (DOCKET) is

the official United States Environmental Protection Agency

(EPA) database for tracking and reporting on civil judicial

and administrative enforcement actions. EPA developed

DOCKET to track the life-cycle of an enforcement action

from its initiation to its conclusion. The Office of

Enforcement and Compliance Assurance (OECA) provides

policies and procedures for the DOCKET system, while

EPA regions and Headquarters’ offices are responsible for

entering and maintaining information within the system.

OBJECTIVE The audit objective was to assess whether DOCKET

contained accurate and reliable data for managing

enforcement actions, as well as reporting on environmental

progress.

RESULTS IN BRIEF EPA under-reported the environmental impact of

enforcement actions under the Government Performance

and Results Act (GPRA). Our audit disclosed that 69

percent of the applicable fiscal 2000 pollutant records

contained blank pollutant amount fields. The pollutant

amount field should have contained amounts used to

compute and report pollutant reductions under GPRA. 

Additionally, our audit determined the DOCKET system, as

a whole, contained significant instances of inaccurate and

incomplete data. Specifically, 94 percent of the cases

reviewed within DOCKET contained at least one error in a

key field. Until management takes decisive steps to address

particular data weaknesses, neither Congress, the public,

nor EPA management should depend on the DOCKET

system as a reliable source of environmental data.

OECA is implementing a replacement system for DOCKET,

the Integrated Compliance Information System (ICIS), for

the express purpose of tracking and managing enforcement

compliance cases. However, if improvements are not made
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so that ICIS can avoid the problems encountered with

DOCKET, enforcement data quality will continue to suffer. 

In order for ICIS to adequately meet user needs and be a

meaningful source of information, in accordance with

GPRA, the multiple causes that contributed to incomplete

and inaccurate data in DOCKET need to be addressed. 

Factors contributing to the poor data quality included a

cumbersome system that lacks the functionality needed to

manage cases; inadequate and outdated policies,

procedures, and guidance; and the absence of

comprehensive reviews.

RECOMMENDATIONS Due to the nature of the audit findings, OECA, as well as

the 10 regions, Headquarters’ Mobile Source Enforcement

Branch, and Headquarters’ Toxics and Pesticides

Enforcement Division, will need to implement corrective

actions to effectively address these weaknesses. In

particular, we recommend that the Assistant Administrator

for Enforcement and Compliance Assurance improve overall

polices and procedures for: computing pollutant related

information, performing quality assurance, disseminating

training, and monitoring the implementation of the policies. 

The Assistant Administrator also needs to (1) develop and

implement a process to ensure system requirements

identified by the users are included in the design and

implementation of the system being developed to replace

DOCKET, and (2) develop and apply a scrubbing process

to the DOCKET data used to populate the new system to

ensure it is accurate and complete.

We also made several recommendations to the Regional

Administrators and the Director of Toxics and Pesticides

Enforcement Division and the Chief of the Mobile Source

Enforcement Branch. These recommendations entail

establishing regional policies and procedures that (1) ensure

compliance with Headquarters’ policies and procedures;

(2) outline required cross-organizational lines of authority

and communication; and (3) implement a monitoring

process to ensure regional policies and procedures are

followed, continuously reevaluated, and improved.
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AGENCY COMMENTS In general, the Agency officials agreed with the conditions

AND OIG EVALUATION identified in the report. However, the Agency believes the

report overstates the unreliability of the data. In a

memorandum dated December 19, 2001, the Agency

proposed separating Judicial (Civil) cases from

Administrative cases. The Agency believed this would

provide a better representation of DOCKET data reliability

because certain fields only apply to Judicial cases. 

We employed a methodology that conservatively assessed

the overall reliability of the data within DOCKET. We

evaluated each field based on whether it was applicable to

the particular case. For example, if a field was not

applicable and was left blank, we accepted it as correct. 

This methodology provided a very conservative error rate in

comparison to separately evaluating cases applicable to a

specific situation. We obtained concurrence on the

methodology from Agency officials and the General

Accounting Office (GAO) prior to beginning the review. 

We believe that data unreliability is not overstated, based on

the significant error rates uncovered for most of the key

fields reviewed.

Agency officials stated they would respond to the specific

recommendations upon receipt of the final report. 
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TABLE OF CONTENTS

Page

EXECUTIVE SUMMARY .................................................... i

CHAPTERS

1- INTRODUCTION ..................................................... 1

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

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

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

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

Criteria ............................................................. 4

2- GPRA ENVIRONMENTAL IMPACT UNDER-REPORTED .................... 5

EPA Under-Reported Environmental Impact ................................. 5

GPRA-Related Fields Inaccurate, Incomplete, or Unsupported .................... 6

Existing Problems Affect Future Reporting .................................. 7

Agency Comments and OIG Evaluation ..................................... 7

3- UNRELIABLE DATA IMPAIRS USABILITY OF SYSTEM INFORMATION ..... 11

DOCKET Data Inaccurate, Incomplete, or Unsupported ....................... 11

Deletion of Cases Not Properly Controlled .................................. 14

Input Errors Do Not Play Significant Role .................................. 14

Agency Comments and OIG Evaluation .................................... 15
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4- CORRECTIVE ACTIONS NEEDED PRIOR TO

 IMPLEMENTING REPLACEMENT SYSTEM ........................... 19

Poor Data Quality May Continue In ICIS ................................... 19

Causes for Unreliable DOCKET Data Need to be Addressed .................... 20

System Not Used To Manage ............................................ 21

DOCKET Policies, Procedures, and Guidance Were Outdated 

 and Inconsistent .................................................... 21

Guidance Not Provided for Addressing Pollutant Information ................... 22

Quality Assurance Reviews Not Performed ................................. 23

Policies and Procedures Need Improvement ................................. 23

Recommendations .................................................... 24

Agency Comments and OIG Evaluation .................................... 27

EXHIBIT

DETAILS ON SCOPE, METHODOLOGY, AND CRITERIA .................. 29

APPENDICES

1- OECA COMMENTS TO DRAFT REPORT ................................ 33

2- REGIONAL INPUT FOR SYSTEM ENHANCEMENTS FOR ICIS ............. 39

3- REPORT DISTRIBUTION ............................................. 41
Report No. 2002-P-00004

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CHAPTER 1

INTRODUCTION

Purpose The audit objective was to assess whether the National

Enforcement Docket System (DOCKET) contained

accurate and reliable data for managing enforcement

actions, as well as reporting on environmental progress.

Background In October 1998, several Committee Chairmen in the House

of Representatives tasked the Inspector General (IG)

community with verifying and validating selected data

sources and information systems used to report on the

Agency’s Government Performance and Results Act

(GPRA) annual performance goals. In December 1998, the

Senate also suggested the IG community verify and validate

the accuracy and reliability of the performance data used to

report on the Agency’s GPRA annual performance goals.

DOCKET is EPA’s official database for tracking and

reporting on civil judicial and administrative enforcement

actions. EPA developed this national, automated

information system to track civil litigation and

administrative actions from case development to closure

under all environmental statutes. DOCKET includes facility

and defendant information, and can be used to track all

major milestone events of a case. For example, DOCKET

can track complaints, settlements, and Supplemental

Environmental Projects (SEP). The Office of Enforcement

and Compliance Assurance (OECA) has responsibility for

providing policies and procedures for the DOCKET system,

while both EPA Headquarters and regional offices are

responsible for entering and maintaining information within

the system.

The Consent Decree Tracking System (CDETS) is a

national database closely related to the DOCKET system. 

CDETS tracks facility and compliance schedule information

of consent decrees. The system assists the tracking,
Report No. 2002-P-00004

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managing, and reporting of compliance status information

from the point of initiation until facilities are in compliance

and the decree is terminated. Because of this close

relationship, CDETS was included in the data accuracy and

reliability work of this audit.

In 1999, Congress asked the National Academy of Public

Administration to conduct an independent evaluation of

state and federal enforcement data and to make

recommendations to Congress, EPA, and the states

regarding actions necessary for ensuring public access to

accurate, credible, and consistent enforcement data. The

Academy’s June 2001 report, “Evaluating Environmental

Progress: How EPA and the States Can Improve the

Quality of Enforcement and Compliance Information,”

pointed out the increasing importance of reliable

enforcement and compliance data. The report indicated

that good information was rapidly becoming an essential

element for environmental protection, and that reliable

enforcement and compliance data should be considered a

prerequisite for all environmental programs. The

Academy’s report emphasized that reliable data was

essential for EPA and the state environmental agencies to

identify environmental problems, set goals, select tools to

remedy problems, measure their progress, analyze the

effectiveness of their programs, and adjust their strategies

accordingly.

Furthermore, the report stated:

“Good information is fundamental to effective

management and public confidence in government

agencies. For the last three decades, however, EPA

and most state environmental agencies have relied

on data about enforcement activities that do not

actually show how well the environment is doing, or

how well the regulated community is obeying

environmental laws. To the extent that these data

measure enforcement or other governmental

performance, they are much more likely to be

misleading than useful.”
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The Academy panel concluded that current data on

enforcement and compliance, and the systems used to

collect and disseminate that data, were inadequate to meet

the needs of the next generation of environmental programs.

Scope and Methodology The primary focus of the audit was to evaluate the reliability

of specific DOCKET data elements used to track and

manage enforcement activities, as well as support

externally-reported GPRA performance measures and

annual performance goals. We conducted audit fieldwork

from November 2000 through June 2001, visiting all

10 EPA regional offices, Headquarters’ Mobile Source

Enforcement Branch, and Headquarters’ Toxics and

Pesticides Enforcement Division (hereafter referred to

collectively as “regions”). We conducted this audit in

accordance with Government Auditing Standards, and

requested and reviewed applicable documentation governing

DOCKET. For further discussion of our scope and

methodology, refer to the scope and methodology section

included in the Exhibit.

Prior Audit Coverage In March 2001, the Office of Inspector General (OIG) 

issued a report entitled “Enforcement: Compliance with

Enforcement Instruments” (Report No. 2001-P-00006). 

The audit found that:

• OECA’s annual accomplishment reports did not

accurately represent the actual environmental

benefits resulting from enforcement activities, and

associated performance measures were not sufficient

to determine the program’s actual accomplishments.

• Regions did not always adequately monitor

compliance with enforcement instruments nor did

they always consider further enforcement actions.

For more information, refer to the prior audit coverage

section included in the Exhibit.

The Agency is in the process of responding to this report.
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Criteria We used Agency policies and procedures to form a

framework of prudent practices for processing DOCKET

data. The following criteria were of particular importance

to our audit field work and analysis:

• Procedures for Maintenance of Enforcement Docket

System

• Enforcement DOCKET Maintenance

• Quality Assurance of Active Civil Enforcement Case

DOCKET

• Support of the Enforcement DOCKET for

Information Management in OECA

• Clarification of Administrative Order Tracking

Requirements

• Tracking EPA Administrative Action in DOCKET 

• Guidance for Case Conclusion Data Sheet (CCDS)

Reporting Improvements

For summaries of each of these policy memorandums, refer

to the criteria section included in the Exhibit.
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CHAPTER 2

GPRA ENVIRONMENTAL IMPACT UNDER-REPORTED

EPA under-reported the environmental impact of

enforcement actions under GPRA. This occurred due to

incomplete data in the DOCKET System (see Chapter 3). 

In particular, DOCKET data was not accurate and complete

for providing information on enforcement actions that

resulted in pollutant reductions. As a result, the information

provided to Congress, the public, and EPA management

was not reliable.

EPA Under-Reported Incomplete pollutant information prevented EPA from

Environmental Impact accurately measuring environmental impact. According to

Section II of EPA’s fiscal 2000 Annual Report, EPA

enforcement actions resulted in a reduction of

approximately 714 million pounds of pollutants. We

reviewed the methodology used to report pollutant

reductions stemming from enforcement actions and found

pollutant amount data incomplete.

EPA uses DOCKET data to estimate the amount of

pollutant reduced as a result of enforcement actions. This

process requires pollutant amount information to be

completed for all enforcement actions reported as SEP or

compliance action pollutant reductions. EPA calculates

pollutant reduction estimates by selecting records that have

pollutant reductions associated with a SEP or compliance

action. EPA only includes a record in the calculation if it

has both the Pollutant Name and Pollutant Amount. 

We selected the pollutant records associated with SEP or

compliance action reductions. For the records selected, we

tested the relationship between the Pollutant Name and

Pollutant Amount fields to determine how many pollutant

records did not have either a Pollutant Name or Pollutant

Amount. All pollutant records had Pollutant Names. 

However, a significant number of records did not have
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Pollutant Amounts recorded, and consequently were not

used in the calculation of pollutant reductions. The

following table shows our results for fiscals 1998, 1999, and

2000.

Fiscal Year

Number of Pollutant

Records Associated with SEP &

Compliance Action Pollutant

Reductions Identified *

Percent of Records

Without Pollutant

Amounts Entered

1998 1,738 62%

1999 1,561 56%

2000 1,476 69%

* NOTE: The number of pollutant records is different from the number of enforcement actions because

each enforcement action case can generate multiple pollutant records.

As noted in the table, in fiscal 2000, 69 percent of the

pollutant records identified as SEP reductions or

compliance action reductions did not contain pollutant

amount information in DOCKET. As a result, EPA could

not accurately quantify the estimated environmental impact

of enforcement actions and, most likely, understated

progress made in reducing pollutants.

GPRA-Related Fields Our review of 53 key fields disclosed that several fields

Inaccurate, Incomplete, used for computing GPRA results were inaccurate,

or Unsupported incomplete, or unsupported. We found that the following

GPRA-related fields contained among the highest

occurrences of inaccurate, incomplete, or unsupported data.
Report No. 2002-P-00004

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DOCKET Screen Input Field Name Projected Statistical Error Rate (%)

Units 54%

Amount Pollutant 52%

Media 52%

Pollutant ID/case 51%

Percent 51%

Frequency 51%

Pollutant Name 43%

NOTE: These fields are defined within the table in Chapter 3.

Existing Problems Affect EPA’s current understatement of actual performance results

Future Reporting could result in management setting lower, future

performance targets. Moreover, the high instance of

missing data prevents EPA from (1) measuring the

effectiveness of environmental policy, and (2) optimally

directing national environmental efforts. With more reliable

measurement data, EPA will have the potential to set more

realistic and progressive targets for enforcement actions that

result in pollutant reductions. Finally, management will be

able to focus on enforcement actions that generate the

greatest environmental impact.

Management intends to use DOCKET as the baseline for

populating a replacement system – the Integrated

Compliance Information System (ICIS). Therefore, if

management does not address missing and inaccurate

DOCKET data in a prompt manner, the problems will

continue in ICIS.

Chapter 4 provides further details, including causes of the

DOCKET inadequacies and recommendations for corrective

actions.

Agency Comments The Agency officials agreed with the problems

and OIG Evaluation we identified. They also concluded there has been

significant under-reporting of pollutant reductions. 

However, they believe that the understatement does not
Report No. 2002-P-00004

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warrant calling the data unreliable. They believe that

understating the impact is preferable and more credible than

overstating it, and that the data should just be considered an

underestimate.

We concur that it is preferable and more credible to be

conservative when providing estimates. However, we

believe that estimates should be based on a consistent

methodology that:

• provides a reasonable assurance that the majority of

the applicable data is included, and

• the absence of any data would not have a material

impact on decision-making.

This is not the case based on the Agency’s own belief that

the pollutant reduction estimates have been significantly

under-reported. For example, GPRA data is used to assess

what EPA accomplishes over a set period of time and is also

used for establishing a baseline for future improvements. 

By setting the baseline so low, perceived performance

improvements can be achieved, without actually improving

performance, by including a larger percentage of the

applicable data in the future year’s calculation. The same

scenario applies to using the data internally for managing. 

At the Agency’s request, we made changes to Chapter 2 to 

clarify that the data contained in pollutant-related data fields

are estimates rather than actuals. 

Additionally, Agency officials indicated they were unsure

how inaccurate, incomplete, or unsupported DOCKET data

included within fields utilized for computing GPRA results

(GPRA-related fields) could affect those results. 

We believe that employing inaccurate, incomplete, or

unsupported DOCKET data to compute GPRA results will

render inaccurate outcomes.

The Agency indicated that they developed a training module

to disseminate the information contained in the pollutant
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reduction estimating guidance. Management assured us that

regional training would be completed by the fourth quarter

of fiscal 2002.
Report No. 2002-P-00004

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CHAPTER 3

UNRELIABLE DATA IMPAIRS USABILITY OF

SYSTEM INFORMATION

DOCKET contained significant instances of inaccurate and

incomplete data. Many crucial fields were inaccurate and

incomplete, thereby creating a questionable baseline for

managing the national enforcement program and assessing

EPA’s environmental performance. Specifically, 94 percent

of the cases reviewed within DOCKET contained errors in

key fields. Therefore, neither Congress, the public, nor

EPA management should depend on the DOCKET system

as a reliable source of environmental data on enforcement

actions. The seriousness of the problem is compounded by

the fact that EPA is making an increasing amount of

DOCKET data available to the public via EPA Internet

websites. Factors contributing to poor data quality included

a cumbersome system that lacks functionality needed to

manage cases; inadequate and outdated policies,

procedures, and guidance; and the absence of

comprehensive quality assurance reviews.

DOCKET Data Inaccurate, Analysis of statistical sample results showed that 

Incomplete, or Unsupported 94 percent of DOCKET cases contained at least one error

within the 53 key fields reviewed. Both the OIG and OECA

management believed these 53 fields were critical to

managing the enforcement programs. These fields identified

key milestone dates, as well as quantitative information

related to pollutants, penalties, SEPs, and cost recovery. 

The 53 key fields included three fields which OECA

management specifically requested us to review.
Report No. 2002-P-00004

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67.9%

20.8%

11.3%

Error Rate > 10%

Error Rate > 3% & <= 10%

Error Rate <= 3%

Percent Distribution of Field Error Rates

We verified these data elements to source documentation

(detailed information available upon request). Our field

work disclosed that more than 88 percent (88.7% = 67.9%

+ 20.8%) of the key fields had an error rate greater than

3 percent, and just under 68 percent had an error rate

greater than 10 percent, as shown in the accompanying

chart. 

Our review disclosed that most key data fields were

inaccurate, incomplete, or unsupported. As a result, the

system often lacked data needed by management to

(1) identify and track cases, and (2) report accurate

performance information to Congress. The following table

identifies the data elements reviewed with error rates

greater than 30 percent.
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DOCKET Screen Input 

Field Name

Projected Statistical

Error Rate (%)

Field Definition

Case Summary 71% A summary of the violation(s), environmental

problem(s), and a description of the cause(s) of action

(basis of legal action). The Case Summary should

provide:

• A brief summary of the nature of the matter (civil

or administrative) and the problem to be addressed.

• The name of principal defendant(s) and type and

number of defendant(s).

• A summary of relief requested.

• Any special facts or circumstances relevant to the

case. 

Units * 54% The measure used for the amount of reduction or

elimination of each pollutant or waste.

Closed 54% When all conditions, terms, and monetary requirements

of the order or the settlement document have been met,

the case is considered closed. A case may also be

closed if no further action is contemplated by EPA.

Amount Pollutant * 52% The amount of reduction or elimination of each

pollutant or waste in pounds, kilograms, or liquid

measure.

Media * 52% The media where the pollutants or waste were

emitted/discharged (e.g., land, water, air).

Pollutant ID/case * 51% The pollutant identification number or code assigned to

each pollutant selected.

Percent * 51% The percent of pollutant or waste reduced or

eliminated.

Frequency * 51% The frequency measure (in units of time) used for the

amount of reduction or elimination of each pollutant or

waste.

Pollutant Name * 43% The waste material, substance, or chemical involved at

the facility in violation at the case level. At the

settlement level, the field is used to identify the

pollutants impacted by the physical actions taken.

* Fields used for GPRA purposes. 

The error rates for the three fields specifically requested by

OECA Senior Management were: 71 percent for Case

Summary, 29 percent for Court Docket Number, and

21 percent for Judicial District.
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Only reliable information should be shared with Congress

and the public. These error rates are unacceptable if EPA

plans to use this data to address Congressional and public

needs. Moreover, the degree of incomplete or inaccurate

system data hampers the ability to successfully measure

enforcement actions.

Deletion of Cases Not OECA and regional management did not enforce consistent

Properly Controlled procedures to ensure deletions of enforcement cases were

properly documented, authorized, and controlled. OECA

did not have a policy that required written justification and

management authorization prior to deleting a case from the

system. Consequently, no regional policies existed to

ensure internal controls were applied when deleting case

records. Our regional field work disclosed numerous

instances where cases were deleted without proper

authorization and support.

Currently, regions use various local systems to track the

status of cases, rather than relying on DOCKET data as a

management tool. However, OECA is implementing a

replacement system, ICIS, for the express purpose of

tracking and managing enforcement actions. With the

introduction of ICIS, regions will be expected to eliminate

the redundant systems. As a result, the reliability of data in

the new system will play an even larger role for properly

tracking the status of cases. Therefore, management must

establish and implement consistent, effective controls over

the deletion of case records or ICIS will inherit and

perpetuate the same data problems.

Input Errors Do Not We noted that input errors were not instrumental in causing

Play Significant Role the inaccuracy and incompleteness of the data. To

determine the input error rate, we verified the contents of

162 fields to the applicable input documents. The 162 fields

were selected based on our knowledge of DOCKET and

CDETS, and on discussions with OECA representatives.

These fields include the 53 key fields previously discussed. 

A field was counted as an error if the contents of the

DOCKET field did not match the input document.
Report No. 2002-P-00004

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Less than 14 percent of the fields selected had an error rate

greater than or equal to 3 percent, and less than 2 percent

had error rates greater than or equal to 5 percent. The

following table shows the three fields with error rates

greater than or equal to 5 percent. Based on these results,

we concluded that input errors did not have a substantial

impact on the inaccuracy and incompleteness of DOCKET

data.

DOCKET Screen Input

Field Name

Projected

Statistical Error

Rate (%)

Complaint/AO (Administrative

Order) Issued (Date Field)

5.86%

Law/Section 5.52%

Lead EPA Attorney 5.17%

Details regarding the results of this review will be provided

upon request.

Chapter 4 provides further details, including causes of the

DOCKET inadequacies and recommendations for corrective

actions.

Agency Comments Agency officials agreed with the problems we identified.

and OIG Evaluation However, management believes the report overstates the

unreliability of the data. In a memorandum dated December

19, 2001, the Agency proposed separating Judicial (Civil)

cases from Administrative cases. The Agency believed this

would provide a better representation of DOCKET data

reliability because certain fields only apply to Judicial cases. 

Management is correct in stating that certain fields only

apply under specific circumstances related to each case. In

addition to the fields that are only applicable to Judicial

cases, some fields are only applicable to Administrative

cases, cases with SEPs, Multi-Media cases, etc.. 

We employed a methodology that conservatively assessed

the overall reliability of the data within DOCKET. We
Report No. 2002-P-00004

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evaluated each field reviewed based on whether it was

applicable to the particular case. If a field was not

applicable and was left blank, then we accepted it as correct. 

This methodology provided a very conservative error rate in

comparison to separately evaluating cases applicable to each

specific situation. We obtained concurrence on the

methodology from Agency officials and the General

Accounting Office (GAO) prior to beginning the review. 

We disagree with the Agency’s specific examples to support

separating Judicial from Administrative cases because the

fields listed in its response are not solely applicable to Civil

Judicial Cases. For example, the Case Summary field is also

required for Administrative Cases based on section 2.1 of

the Agency’s DOCKET User’s Manual and the Agency’s

Administrative Case Data Form, issued by Headquarters. 

The Pollutant Name field is optional (not required) for both

Judicial and Administrative Cases according to sections 3.4,

3.25, 3.28, & 3.29 of the same manual. Likewise, the

Penalty By Statute field applies to both Judicial and

Administrative cases as long as they are a multi-media case

with a penalty. To ensure that we did not overstate any of

the reported error rates, we double-checked our work. We

did not find problems specific to this situation. However,

we did find and correct errors affecting the Penalty by

Statute field caused when the results data was transferred

from Word Perfect to Lotus. 

We believe the unreliability of data is not overstated, based

on the significant error rates uncovered for most of the key

fields reviewed. 

We provided the results of our review at the case level so

the Agency could break out the results by Civil and

Administrative Cases. As such, management can perform

further analysis that they deem to be of additional benefit.

The Agency also stated that they believe the data in

DOCKET is adequate to track the status of Civil Judicial

and Administrative cases. 
Report No. 2002-P-00004

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We believe that for the data to be useful for managing

purposes, it needs to be reliable. Based on the significant

error rates uncovered for most of the key fields reviewed,

we believe the DOCKET data is not adequate for tracking

the status of Civil Judicial and Administrative caseload. 

The results of our fieldwork indicate that Headquarters is

the primary user of collected DOCKET data, and that most 

regions use DOCKET predominately as a reporting system

to EPA Headquarters. Regions input the information into

DOCKET, even though it does not meet their needs,

because they have been directed to do so by Headquarters. 

The data fields reviewed were key elements for managing

enforcement actions, based on a consensus between OECA

management and the OIG. In addition to quantitative

information, these fields included data used specifically for

tracking the status of the cases, such as milestone dates. 

The fact that resources are dedicated to collecting data that

is primarily used by Headquarters, rather than what the

regions need to manage, substantiates the importance of this

data to Headquarters.

The Agency requested the report be clear about the source

of the problems so that corrective actions could be targeted

appropriately. We identified what we believe to be the root

causes within Chapter 4 of the report. We focused our

recommendations, also included in Chapter 4, on corrective

actions to address those causes.

Agency officials also indicated that they have never

experienced problems due to the absence of procedural

controls for deleting cases from the system. They stated

that when a case is deleted, it is not critical to managing

their enforcement program.

We found that the Agency does not have compensating

controls in place to determine if cases were improperly

deleted. We believe it is important to apply proper internal

controls to ensure the integrity of system data. Instituting a

standard control practice becomes even more critical with

the advent of ICIS, because the regions will be expected to
Report No. 2002-P-00004

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use it to manage and track the status of cases rather than

using stovepipe systems.
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CHAPTER 4

CORRECTIVE ACTIONS NEEDED PRIOR TO IMPLEMENTING

REPLACEMENT SYSTEM

OECA is implementing a replacement system for DOCKET,

the Integrated Compliance Information System (ICIS), for

the express purpose of tracking and managing enforcement

actions. If improvements are not made to keep ICIS from

having the same problems as DOCKET, enforcement data

quality will continue to suffer. Due to DOCKET’s lack of

functionality, regions only used it as an information

reporting system to EPA Headquarters, and not as an

enforcement case management system. If ICIS does not

fulfill that role, then regions will continue to expend

additional resources to maintain redundant systems for their

particular managing needs.

Poor Data Quality Poor enforcement data quality will continue if EPA’s new

May Continue In ICIS enforcement system, ICIS, does not meet the regions’ needs

for managing enforcement actions on a day-to-day basis. 

Because of the difficulties encountered with DOCKET,

users primarily relied on their regional systems for managing

cases and placed less importance on the quality of data

entered in DOCKET. The regions have identified critical

functions they deem necessary to meet management

requirements and improve data quality in ICIS. With the

introduction of ICIS, regions will be expected to eliminate

the redundant systems. However, if EPA does not address

the user’s needs within ICIS, the new system will perpetuate

the same data quality concerns.

Regional personnel consistently acknowledged the

importance of having a single system for tracking and

managing enforcement actions. As such, all regions

participated in OECA focus group discussions to identify

ICIS system requirements. In addition, some regions

provided us with input regarding system improvements. A

few of the regional suggestions were:
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• Establish single point of entry to satisfy all

environmental systems’ data requirements.

• Establish security controls to protect high profile

litigation or high dollar cases.

• Establish automatic notification of missed milestones

(e.g., e-mail).

See Appendix 2 for a complete listing of regional

suggestions.

If ICIS is not designed to meet user needs, then regions will

continue to expend additional resources to maintain

redundant systems. We surveyed EPA to determine the

extent regions were developing and maintaining independent

systems for enforcement and compliance tracking. We

received responses from all regions and found that they have

already spent $290,000 to develop 19 redundant, “stovepiped” systems to meet their needs, and have budgeted

approximately $1.3 million over the next 5 years to maintain

those 19 systems. We believe the regions could better use

these funds to support environmental programs.

Causes for Unreliable Our review disclosed that multiple causes contributed to

DOCKET Data Need incomplete and inaccurate data in DOCKET. Specifically,

to be Addressed we identified the following main factors:

• DOCKET was not used to manage, because it was

considered cumbersome and lacked functionality.

• DOCKET’s policies, procedures, and guidance were

outdated and inconsistent.

• OECA did not provide guidance on identifying and

calculating pollutant information.

• Regions did not comprehensively review

enforcement data.
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• Regional policies and procedures were inadequate

and inconsistent.

Details on each of these areas follow.

System Not Used to Manage Regions did not use DOCKET on a daily basis for

enforcement case management, because users said they

considered the system to be cumbersome, non-user-friendly,

and lacking the functionality needed to manage. Regions

were primarily using DOCKET as an information reporting

system to EPA Headquarters.

DOCKET’s Policies, OECA had not updated the DOCKET User’s Guide and

Procedures, and Guidance Data Dictionary to identify critical data elements essential

Were Outdated and for performance reporting. Many crucial data elements

Inconsistent were designated as optional, resulting in many database

fields being unpopulated. For example, the current

DOCKET User’s Guide states the pollutant fields are

optional. Therefore, pollutant information is often not

reported, even though such data factors into

Congressionally-reported performance measures. The error

rates for these particular fields are listed in Chapter 2.

In addition, inconsistencies between DOCKET’s User’s

Guide, Data Dictionary, and input forms could lead to

confusion by users. Some examples of inconsistencies are:

• The Administrative Case Data Form indicates that

fields are required, although the detailed section of

the User’s Guide indicates they are not required.

• The Administrative Case Data Form indicates that

certain fields included on the form are not required,

even though the general section of the User’s Guide

indicates they all are required.

• The required fields per the Data Dictionary do not

always coincide with the User’s Guide required

fields.
1

 Report entitled, “Review, Analysis, and Recommendations

for Improvement of Office of Enforcement and Compliance Assurance

Case Conclusion Data Sheets – Final Report,” dated November 29,

1999, Page 1.

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Furthermore, DOCKET does not force users to input data

into many key fields. OECA indicated that the User’s

Guide and Data Dictionary define required fields as those

for which the system demands data input. However,

prudent practices should ensure that fields which senior

management have identified as key to managing the

program and reporting results coincide with the mandatory

entry fields defined in the application system. Because

DOCKET’s system requirements do not always correspond

with management’s desires, users cannot always trust the

User’s Guide or Data Dictionary to determine what data

they must enter into the system.

Guidance Not Provided Although EPA recently issued an extensive training manual

for Addressing regarding pollutant information, the regions have not

Pollutant Information implemented the guidance. Our field work concluded that

personnel consistently provided incomplete or inaccurate

pollutant information and needed to be trained. OECA

reached similar conclusions as a result of independent

studies, although they did not issue any comprehensive

training guidance until January 2001. During the last

several years, OECA has enhanced DOCKET to

accommodate input of CCDS information, created a new

CCDS, and initiated additional reviews to address

weaknesses in their information reporting methodology. 

OECA’s latest review1 found that incomplete data was a

major issue for several key data elements, such as pollutant

name, amount, and units.

Whereas OECA’s recent manual included guidance on how

to identify and calculate pollutant information, management

did not identify an implementation date for using the new

procedures. Consequently, the regions did not apply the

guidance. OECA stated that a program for delivering onsite

training is being developed. 
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To accurately and consistently compute pollutant

information associated with compliance actions, field

inspectors must be aware of the information needed for the

computations outlined in the guidance. In some cases, these

field inspectors are state employees. If the state field

inspectors are not advised of the data necessary for the

computations associated with potential compliance actions,

then it is conceivable that not all of the necessary

information will be collected during the inspection. Without

this information, EPA may still have problems accurately

and consistently computing pollutant information.

Quality Assurance Reviews Regions relied on inconsistent, limited reviews rather than

Not Performed systematic and comprehensive quality assurance reviews. 

Although OECA published procedures for conducting

monthly quality assurance reviews of all DOCKET fields,

the regions were not adhering to the policy. The policy

requires that the lead attorneys review and update all data

fields using the Monthly Case Update Report. In addition,

the User’s Guide states that the information for completing

some of the key fields will be provided on the Monthly Case

Update Report. We found that the regions were not using

this report and, as a result, the information for these fields

were often not completed or reviewed.

None of the regions had formal policies and procedures

which assigned responsibility and accountability for

conducting quality reviews. The informal reviews merely

consisted of reconciling case names in stovepipe systems to

DOCKET and/or performing high-level reviews of limited

fields. Furthermore, we found that whenever regions

distributed reports for quality assurance purposes, the

reports did not contain all data fields. The inconsistent and

limited nature of quality assurance reviews perpetuated high

error rates in DOCKET.

Policies and Procedures The regions did not have formal policies and procedures

Need Improvement to implement OECA’s policies, procedures, and guidance

for all phases of enforcement data processing (i.e.,

identification, collection, inputting, deletion, quality

assurance, etc.). As a result, regional management had not
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formalized its expectations, nor implemented a formal

mechanism to ensure that personnel processed enforcement

information in a consistent manner. The lack of formalized

policies and procedures led to inconsistencies in the way

enforcement data was processed from region to region, as

well as within regions.

Recommendations We recommend the Assistant Administrator for

Enforcement and Compliance Assurance:

1. Develop and implement a process to ensure system

requirements, identified by the users at Headquarters

and within the regions, are included in the design

and implementation of the system being developed

to replace DOCKET.

2. With regards to OECA’s policies, procedures, and

guidance related to DOCKET, as well as guidance

related to pollutant information:

a. Revise, consolidate, issue, and monitor the

implementation of all policies, procedures,

and policy memorandums related to

DOCKET. The policies and procedures

should:

(1) Be based on management’s needs and

how the data will be used;

(2) Address all phases of DOCKET/new

system (ICIS) data processing, e.g.,

identification, collection, input,

deletion, quality assurance, etc.;

(3) Assign authority, responsibility, and

accountability for each of the phases

and processes; and

(4) Ensure all data elements applicable to

an enforcement action are completed

timely, accurately, and consistently.
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b. Develop and implement training coinciding

with the issuance of new policies and

procedures for all applicable personnel 

(e.g., attorneys, data entry, technical

representatives, etc.).

c. Revise the User’s Guide, Data Dictionary,

and input forms to eliminate inconsistencies

and to identify management requirements

related to the data elements.

d. Formally communicate and reach agreement

with the states regarding what information

needs to be collected during inspections that

may result in compliance actions. This

information is necessary, per the guidance, to

complete the CCDS. 

3. In regard to the Quality Assurance Process:

a. Develop and implement policies and

procedures that establish a Quality

Assurance process. OECA management 

should periodically monitor and review the

Quality Assurance process. The Quality

Assurance process should:

(1) Assign authority, responsibility, and

accountability for Quality Assurance

for each case to the person most

knowledgeable about the case

(attorney); 

(2) Establish and document how often

the procedures should be performed.

The timing of the Quality Assurance

reviews should be tied to

management’s information needs; and

(3) Be monitored and periodically

reviewed by OECA management.
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b. To assist in the identification of missing data,

develop standard reports that will identify

missing or potentially missing data for each

type of case and each relevant segment of

information, (e.g., SEPs, Audit Policy,

pollutant-related information, etc.), and have

the regions review these reports as part of

the Quality Assurance process.

4. With regard to populating and deploying the new

system:

a. Identify those cases that need to be brought

into the new system (ICIS); and

b. Develop and apply a scrubbing process to

the cases identified (prior to populating the

system) to ensure that the data used to

populate the new system is accurate and

complete.

We recommend the Regional Administrators and EPA’s

Director of the Office of Regulatory Enforcement:

5. Develop and implement formal regional policies and

procedures that:

a. Implement OECA’s policies and procedures

effectively and efficiently at each site;

b. Establish lines of authority and

communication across organizational

segments to ensure that the data collected

and maintained within the system is accurate,

complete, timely, and consistent; and

c. Establish a monitoring process to:

(1) Verify the policies and procedures

are being followed,
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(2) Continuously evaluate the efficiency

and effectiveness of the processes,

and

(3) Identify opportunities to improve

processes.

Agency Comments Agency officials agreed with the causes identified in this

and OIG Evaluation report. They pointed out that it would be helpful if we

could identify the inconsistencies we found during our

review. 

We provided them with examples of inconsistencies we

found during our cursory review of the DOCKET User’s

Guide, Data Dictionary, and input forms. However, we

believe that fixing the ones we noted does not fulfill

management’s responsibility to perform their own review

and make applicable corrections. 

Agency officials noted that our report does not present

analysis based on data produced after the issuance of the

guidance (related to estimating pollutant reduction results)

in January 2001.

The sample cases selected were all opened prior to

September 29, 2000. However, we verified the accuracy of

the data, associated with the selected cases, as of the dates

we performed the field work. We conducted field work for

nine of the ten regions after the guidance was issued. The

nine regions we visited after it was issued stated they had

not started using the guidance yet. 

The Agency asked us to clarify that Recommendation 2.d.

refers to the information on the Case Conclusion Data

Sheets for pollutant information. We clarified the

recommendation, as requested.

Agency officials stated that they would respond to the

specific recommendations upon receipt of the final report.
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EXHIBIT

DETAILS ON SCOPE, METHODOLOGY, AND CRITERIA

Scope And Methodology

Congress asked the Inspector General community to both verify and validate the accuracy and

reliability of performance data used to report on the Agency’s GPRA annual performance goals. 

Verifying is the process of determining whether system data is accurate and complete (i.e.,

reliable), whereas validating entails determining whether an agency’s key performance measures

are consistent with its strategic and annual performance goals. Our audit was limited to verifying

the accuracy and reliability of the data within DOCKET. 

We selected two random attribute samples to help assess the accuracy and completeness of

DOCKET data. We selected one sample for active cases and a second sample for deleted cases. 

We used the sample for active cases to perform source document verification for 53 key fields and

input document verification analysis. We used the second sample to review support documents

associated with the justification and authorization of deleted cases.

We also performed analysis of the complete DOCKET Database for edit checks and field

relationships, as defined by the DOCKET Data Dictionary. 

OECA management disclosed they were developing a replacement system for DOCKET entitled

Integrated Compliance Information System (ICIS). As a result, we requested that regions identify

what improvements they would like implemented in the replacement system. We also conducted

a survey to determine the resources regions committed to develop and maintain systems for

managing enforcement actions. We performed this survey because these systems were used in

lieu of DOCKET.

Prior Audit Coverage

In March 2001, the OIG issued a report entitled “Enforcement: Compliance with Enforcement

Instruments,” (Report No. 2001-P-00006). The audit found that:

• OECA’s annual accomplishment reports did not accurately represent the actual

environmental benefits resulting from enforcement activities. For example, an OECA

report stated that fiscal 1999 enforcement actions resulted in the reduction of more

than 6.8 billion pounds of pollutants. However, this may have been an understatement
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or overstatement since: (1) violators did not always comply with the enforcement

instruments, and (2) data was not comprehensive. Also, OECA’s performance

measures were not sufficient to determine the program’s actual accomplishments. 

Consequently, Congress had less useful performance data upon which to base its

decisions.

• Regions did not always adequately monitor compliance with enforcement instruments

nor did they always consider further enforcement actions. Ineffective monitoring was

due primarily to the lack of: (1) guidance detailing how or when to monitor

enforcement instruments, and (2) emphasis OECA placed on monitoring. Ineffective

monitoring may have contributed to the regions not considering further enforcement

actions for noncompliance with enforcement instruments. Consequently, there was a

risk that (1) violations would continue and contribute to environmental harm or

increased health risks, and (2) EPA’s effectiveness, through deterrence, would be

adversely impacted. The report listed instances where EPA had no evidence that

significant violations had been corrected. 

Criteria

Included below are summaries of criteria that were of particular importance to our audit field

work and analysis:

Procedures for Maintenance of Enforcement Docket System

This memorandum, dated April 21, 1983, established the Enforcement Docket System as

the official system for tracking and maintaining summary and status information about civil

and criminal enforcement actions. The document was the official record of all litigation

activity used for:

• Reporting to the Administrator regarding accountability measures, 

• Responding to Congressional inquiries,

• Answering Freedom of Information Act requests, and 

• Performing special analyses. 

According to this source, the Lead EPA Attorney is responsible for completing the case

input forms and giving them to the regional data analyst for assignment of a case number

and initial data entry. The Lead EPA Attorney also has primary responsibility for the

review and update of all active cases. In addition, the document establishes and assigns

the responsibility for the quality assurance function to the Lead EPA Attorney.
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Enforcement DOCKET Maintenance

This policy memorandum, dated April 8, 1988, identified specific responsibilities for the

regional offices and EPA Headquarters. The document stated the primary responsibility

for timeliness, accuracy, and completeness of DOCKET data resided with the Offices of

Regional Counsel. Specifically: 

• Regions were responsible for accurate updates at least monthly;

• Headquarters was responsible for accurate monthly update of Headquartersinitiated data fields;

• Headquarters would not amend regional data entry;

• Headquarters would continue to monitor overall data quality on a monthly

basis for the balance of fiscal 1988, and thereafter on a quarterly basis.

Headquarters would be responsible for bringing discrepancies to the attention

of the Regional Counsel; and

• DOCKET maintenance would be considered part of the annual performance

assessment discussion with Regional Counsels.

Quality Assurance of Active Civil Enforcement Case DOCKET

This policy, dated March 2, 1989, addressed the quality of the data in DOCKET. The

document emphasized EPA’s reliance on DOCKET information to (1) manage

enforcement programs, and (2) respond to internal and external inquiries (e.g., Congress

and the public). Furthermore, the policy decentralized the Agency’s enforcement process

by giving regions the authority and responsibility for initiating and following through on

enforcement actions. 

Support of the Enforcement DOCKET for Information Management in OECA

On October 3, 1994, this policy assigned the Regional Counsels primary responsibility for

entering and maintaining data on all civil judicial and administrative enforcement actions. 

In particular, Regional Counsels were to ensure that: 

• Every civil judicial and formal administrative penalty enforcement case was

entered into DOCKET; 

• All new formal administrative penalty actions, starting with fiscal 1995, were

entered into DOCKET; and

• By the end of the second quarter of fiscal 1995, all administrative penalty

orders that had been issued or filed but not yet concluded, were entered into

DOCKET.
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Clarification of Administrative Order Tracking Requirements

This policy memorandum, dated May 9, 1995, clarified administrative orders and, in

particular, addressed the inefficiencies of dual data entry - that is, entering the same data

into DOCKET and various program databases. This policy emphasized that all

administrative penalty actions were to be entered into DOCKET. The document also

reemphasized that DOCKET was to be the primary source for Enforcement data. 

Tracking EPA Administrative Action in DOCKET

This policy memorandum, dated March 6, 1996, clarified that all EPA administrative

penalty orders and orders for cost recovery, issued in fiscal 1996 and subsequent years,

were to be entered into DOCKET. The document also reaffirmed that DOCKET was the

official system for tracking and reporting on EPA civil judicial and administrative

enforcement actions.

Guidance for Case Conclusion Data Sheet (CCDS) Reporting Improvements

This guidance, dated January 2, 2001, provided instructions and examples for collecting

and computing pollutant-related enforcement data, used to describe the impact of

enforcement actions on the environment.
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APPENDIX 1

OECA COMMENTS TO DRAFT REPORT
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APPENDIX 2

REGIONAL INPUT FOR SYSTEM ENHANCEMENTS FOR ICIS

From December 2000 through May 2001, we visited each EPA Regional Office and

Headquarters. During these visits, we asked each location to provide suggested improvements

they would like to see incorporated into the Integrated Compliance Information System (ICIS).

Regions participated in OECA Focus Groups on the new system (ICIS), where they provided

suggestions for design enhancements to meet their needs. Most regions did not provide a

comprehensive list of suggestions because they had already provided them directly to OECA.

We received a total of 38 responses. All regions did not provide comments. The table below is

not a complete listing of requirements from all locations visited. We grouped similar responses

into categories and ordered the listing based on the number of responses received for each

category. The table below summarizes the comments received. 

Additional Considerations for the Development of ICIS

(* Input Provided By EPA Regions and Headquarters)

Number of Responses

Received Category

10 Improve Report Capabilities 

a. Improve report formats to reduce paper

b. Add capability to detect and report missing data

c. Integrate quality control process into system

7 Integrate Regional Systems’ Capabilities

d. Integrate the capabilities of regional systems such as Compliance

Activity Tracking System (CATS), Super DOCKET, etc..

6 Improve Interface

e. Make data easier to access the data

f. Make Ad-Hoc Queries easier to run

g. Make the screens more user-friendly

5 Improve Search Capabilities

h. Make it easier to use

i. Add the capability to see Defensive Cases

j. Add the capability for managers to see milestones
Additional Considerations for the Development of ICIS

(* Input Provided By EPA Regions and Headquarters)

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4 Add New Features

k. Add automatic notification of missed milestones (e.g., e-mail)

l. Add security to protect high-profile/high-dollar cases

m. Add fields for supplemental referrals

n. Add ability to hotlink to a source document

3 Reduce Duplicate Entry of Data in Multiple Systems

o. Develop an integrated system that shares the data with all other

related systems so that each applicable data element only has to

be entered one time

3 Improve Policy and Procedures

p. Require regions to use

q. Allow entry of data by those most knowledgeable about the case

information

r. Standardize data codes

* NOTE: Not all regions and Headquarters offices provided comments. This list is not a complete listing

of regional and Headquarters requirements. 
Report No. 2002-P-00004

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APPENDIX 3

REPORT DISTRIBUTION

Recipient

Acting Assistant Administrator for Enforcement and Compliance Assurance (2201A)

Office of Inspector General

Inspector General (2410)

Assistant Inspector General for Audits (2421)

Media and Congressional Liaison (2410)

Counsel (2411)

Editor (3A100)

EPA Headquarters

Agency Audit Followup Official (2710A)

Agency Followup Coordinator (2724A)

OECA Audit Liaison (2201A)

Director, Office of Compliance (2221A)

Director, Enforcement Planning, Targeting, and Data Division (2222A)

Director, Office of Regulatory Enforcement (2241A)

Director, Toxics and Pesticides Enforcement Division (2245A)

Director, Air Enforcement Division (2242A)

Regional Offices

Region I: Regional Administrator (RAA)

Director, Office of Environmental Stewardship

Audit Follow-up Coordinator (MIO)

Region II: Regional Administrator

Regional Counsel 

Audit Follow-up Coordinator 

Region III: Regional Administrator (3RA00)

Regional Counsel (3RC00)

Audit Follow-up Coordinator (3PM70)
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Region IV: Regional Administrator

Director, Environmental Accountability Division

Audit Follow-up Coordinator 

Region V: Regional Administrator (R-19J)

Regional Counsel (C-14J)

Audit Follow-up Coordinator (MF-10J)

Region VI: Regional Administrator (6RA)

Regional Counsel (6RA-D)

Director, Compliance Assurance and Enforcement Division (6EN)

Audit Follow-up Coordinator (6MD-RC)

Region VII: Regional Administrator (RA)

Regional Counsel (CNSL)

Audit Follow-up Coordinator (PLMGRFMB)

Region VIII: Regional Administrator (RA)

Regional Counsel (RC)

Assistant Regional Administrator, Office of Enforcement, Compliance,

and Environmental Justice (ENF)

Audit Follow-up Coordinator (TMS-ISP)

Region IX: Regional Administrator (ORA-1)

Regional Counsel (ORC-1)

Audit Follow-up Coordinator (PMD-4)

Region X: Office of Regional Administrator (RA-140)

Office of Regional Counsel

Audit Follow-up Coordinator