Environmental Protection Agency: Actions Needed to Improve Planning, Coordination, and Leadership of EPA Laboratories
Published: 2011-11-17T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: This testimony discusses the research and development activities of the Environmental Protection Agency (EPA) and the findings of our recent report on the agency's laboratory enterprise. EPA was established in 1970 to consolidate a variety of federal research, monitoring, standard-setting, and enforcement activities into one agency for ensuring the joint protection of environmental quality and human health. Scientific research, knowledge, and technical information are fundamental to EPA's mission and inform its standard-setting, regulatory, compliance, and enforcement functions. The agency's scientific performance is particularly important as complex environmental issues emerge and evolve, and controversy continues to surround many of the agency's areas of responsibility. Unlike other primarily science-focused federal agencies, such as the National Institutes of Health or the National Science Foundation, EPA's scientific research, technical support, and analytical services underpin the policies and regulations the agency implements. Therefore, the agency operates its own laboratory enterprise. This enterprise is made up of 37 laboratories that are housed in about 170 buildings and facilities located in 30 cities across the nation. Specifically, EPA's Office of Research and Development (ORD) operates 18 laboratories with primary responsibility for research and development. Four of EPA's five national program offices operate nine laboratories with primary responsibility for supporting regulatory implementation, compliance, enforcement, and emergency response. Each of EPA's 10 regional offices operates a laboratory with responsibilities for a variety of applied sciences; analytical services; technical support to federal, state, and local laboratories; monitoring; compliance and enforcement; and emergency response. Over the past 20 years, independent evaluations by the National Research Council and others have addressed planning, coordination, or leadership issues associated with EPA's science activities. The scope of these evaluations varied, but collectively they recognized the need for EPA to improve long-term planning, priority setting, and coordination of laboratory activities; establish leadership for agencywide scientific oversight and decision making; and better manage the laboratories' workforce and infrastructure. When it was established in 1970, EPA inherited 42 laboratories from programs in various federal departments. According to EPA's historian, EPA closed or consolidated some laboratories it inherited and created additional laboratories to support its mission. Nevertheless, EPA's historian reported that the location of most of EPA's present laboratories is largely the same as the location of its original laboratories in part because of political objections to closing facilities and conflicting organizational philosophies, such as operating centralized laboratories for efficiency versus operating decentralized laboratories for flexibility and responsiveness. Other federal agencies face similar challenges with excess and underused property. Because of these challenges, GAO has designated federal real property as an area of high risk. This statement summarizes the findings of our report issued in July of this year that examines the extent to which EPA (1) has addressed the findings of independent evaluations performed by the National Research Council and others regarding long-term planning, coordination, and leadership issues; (2) uses an agencywide, coordinated approach for managing its laboratory physical infrastructure; and (3) uses a comprehensive planning process to manage its laboratory workforce.
section_title: What GAO Found
paragraphs: EPA has taken some actions but has not fully addressed the findings and recommendations of five independent evaluations over the past 20 years regarding long-standing planning, coordination, and leadership issues that hamper the quality, effectiveness, and efficiency of its science activities, including its laboratory operations. First, EPA has yet to fully address planning and coordination issues identified by a 1992 independent, expert panel evaluation that recommended that EPA develop and implement an overarching issue-based planning process that integrates and coordinates scientific efforts throughout the agency, including the important work of its 37 laboratories. Second, EPA has also not fully addressed recommendations from a 1994 independent evaluation by the MITRE Corporation to consolidate and realign its laboratory facilities and workforce--even though this evaluation found that the geographic separation of laboratories hampered their efficiency and technical operations and that consolidation and realignment could improve planning and coordination issues that have hampered its science and technical community for decades. Third, EPA has not fully addressed recommendations from the independent evaluations regarding leadership of its research and laboratory operations. On the basis of our analysis of EPA's facility master planning process, we found that EPA manages its laboratory facilities on a site-by-site basis and does not evaluate each site in the context of all the agency's real property holdings--as recommended by the National Research Council report in 2004. EPA's facility master plans are intended to be the basis for justifying its building and facilities spending, which was $29.9 million in fiscal year 2010, and allocating those funds to specific repair and improvement projects. Master plans should contain, among other things, information on mission capabilities, use of space, and condition of individual laboratory sites. In addition, we found that most facility master plans were out of date. EPA's real property asset management plan states that facility master plans are supposed to be updated every 5 years to reflect changes in facility condition and mission, but we found that 11 of 20 master plans were out of date and 2 of 20 had not been created yet. EPA does not use a comprehensive planning process for managing its laboratories' workforce. For example, we found that not all of the regional and program offices with laboratories prepared workforce plans as part of an agencywide planning effort in 2007, and for those that did, most did not specifically address their laboratories' workforce. In fact, some regional management and human resource officials we spoke with were unaware of the requirement to submit workforce plans to the Office of Human Resources. Some of these managers told us the program and regional workforce plans were a paperwork exercise, irrelevant to the way the workforce is actually managed. Managers in program and regional offices said that workforce planning for their respective laboratories is fundamentally driven by the annual budgets of program and regional offices and ceilings for full-time equivalents (FTE).

section_title: Letter
paragraphs: I am pleased to be here today to discuss the research and development  activities of the Environmental Protection Agency (EPA) and the findings  of our recent report on the agency’s laboratory enterprise. EPA was  established in 1970 to consolidate a variety of federal research,  monitoring, standard-setting, and enforcement activities into one agency  for ensuring the joint protection of environmental quality and human  health. Scientific research, knowledge, and technical information are  fundamental to EPA’s mission and inform its standard-setting, regulatory,  compliance, and enforcement functions. The agency’s scientific  performance is particularly important as complex environmental issues  emerge and evolve, and controversy continues to surround many of the  agency’s areas of responsibility. Unlike other primarily science-focused  federal agencies, such as the National Institutes of Health or the National  Science Foundation, EPA’s scientific research, technical support, and  analytical services underpin the policies and regulations the agency  implements. Therefore, the agency operates its own laboratory  enterprise. This enterprise is made up of 37 laboratories that are housed  in about 170 buildings and facilities located in 30 cities across the nation.  Specifically, EPA’s Office of Research and Development (ORD) operates  18 laboratories with primary responsibility for research and development.  Four of EPA’s five national program offices operate nine laboratories  with primary responsibility for supporting regulatory implementation,  compliance, enforcement, and emergency response. Each of EPA’s 10  regional offices operates a laboratory with responsibilities for a variety of  applied sciences; analytical services; technical support to federal, state,  and local laboratories; monitoring; compliance and enforcement; and  emergency response.
Over the past 20 years, independent evaluations by the National Research  Council and others have addressed planning, coordination, or leadership  issues associated with EPA’s science activities. The scope of these  evaluations varied, but collectively they recognized the need for EPA to  improve long-term planning, priority setting, and coordination of laboratory  activities; establish leadership for agencywide scientific oversight and  decision making; and better manage the laboratories’ workforce and  infrastructure. When it was established in 1970, EPA inherited 42  laboratories from programs in various federal departments. According to  EPA’s historian, EPA closed or consolidated some laboratories it inherited  and created additional laboratories to support its mission. Nevertheless,  EPA’s historian reported that the location of most of EPA’s present  laboratories is largely the same as the location of its original laboratories in  part because of political objections to closing facilities and conflicting  organizational philosophies, such as operating centralized laboratories for  efficiency versus operating decentralized laboratories for flexibility and  responsiveness. Other federal agencies face similar challenges with  excess and underused property. Because of these challenges, GAO has  designated federal real property as an area of high risk.
This statement summarizes the findings of our report issued in July of this  year that examines the extent to which EPA (1) has addressed the  findings of independent evaluations performed by the National Research  Council and others regarding long-term planning, coordination, and  leadership issues; (2) uses an agencywide, coordinated approach for  managing its laboratory physical infrastructure; and (3) uses a  comprehensive planning process to manage its laboratory workforce. In  preparing this testimony, we relied on the work supporting our July report.  In conducting that work, we reviewed agency documents and  independent evaluations, visited EPA laboratories, interviewed agency  officials, and examined agency databases; our recent report contains a  detailed description of our scope and methodology. All of the work for our  July report was performed in accordance with generally accepted  government auditing standards.
subsections: section_title: EPA Has Not Fully Addressed Findings of Evaluations on Long- standing Planning, Coordination, or Leadership Issues
paragraphs: EPA has taken some actions but has not fully addressed the findings and  recommendations of five independent evaluations over the past 20 years  regarding long-standing planning, coordination, and leadership issues  that hamper the quality, effectiveness, and efficiency of its science  activities, including its laboratory operations.
First, EPA has yet to fully address planning and coordination issues  identified by a 1992 independent, expert panel evaluation that  recommended that EPA develop and implement an overarching issue- based planning process that integrates and coordinates scientific efforts  throughout the agency, including the important work of its 37  laboratories. That evaluation found that EPA’s science was of uneven  quality and that the agency lacked a coherent science agenda and  operational plan to guide scientific efforts throughout the agency.  Because EPA did not implement the evaluation’s recommendation, EPA’s  programs, regional officials, and ORD continue to independently plan and  coordinate the activities of their respective laboratories based on their  own offices’ priorities and needs.
MITRE Corporation, Center for Environment, Resources, and Space, Assessment of the  Scientific and Technical Laboratories and Facilities of the U.S. Environmental Protection  Agency (McLean, Va., May 1994). study, an agencywide steering committee formed by EPA to consider  restructuring and consolidation options issued a report to the  Administrator in July 1994. The steering committee report stated that  combining ORD laboratories at a single location could improve teamwork  and raise productivity but concluded that, for the near term, ORD should  be functionally reorganized but not physically consolidated. Regarding  program office laboratory consolidations, the Office of Radiation and  Indoor Air did not physically consolidate its laboratories but did  administratively and physically consolidate its Las Vegas laboratory with  ORD’s Las Vegas radiation laboratory, and the Office of Prevention,  Pesticides, and Toxic Substances colocated three of four laboratories  with the region 3 laboratory. As for the regional laboratories, the steering  committee’s report endorsed the current decentralized regional model but  did not provide a justification for its position.
National Research Council, Interim Report of the Committee on Research and Peer  Review in EPA (Washington, D.C., National Academies Press, 1995); Environmental  Protection Agency, Office of Inspector General, Regional Laboratories (Washington, D.C.,  Aug. 20, 1997); and National Research Council, Strengthening Science at the U.S.  Environmental Protection Agency: Research-Management and Peer Review Practices  (Washington, D.C., National Academies Press, 2000). technical activities. To date, EPA has not requested authority to create a  new position of deputy administrator for science and technology and  continues to operate its laboratories under the direction of 15 different  senior officials using 15 different organizational and management  structures. As a result, EPA has a limited ability to know if scientific  activities are being unintentionally duplicated among the laboratories or if  opportunities exist to collaborate and share scientific expertise,  equipment, and facilities across EPA’s organizational boundaries.
section_title: EPA Has Not Taken an Agencywide, Coordinated Approach to Manage Its Laboratory Physical Infrastructure
paragraphs: On the basis of our analysis of EPA’s facility master planning process, we  found that EPA manages its laboratory facilities on a site-by-site basis  and does not evaluate each site in the context of all the agency’s real  property holdings—as recommended by the National Research Council  report in 2004. EPA’s facility master plans are intended to be the basis  for justifying its building and facilities spending, which was $29.9 million in  fiscal year 2010, and allocating those funds to specific repair and  improvement projects. Master plans should contain, among other things,  information on mission capabilities, use of space, and condition of  individual laboratory sites. In addition, we found that most facility master  plans were out of date. EPA’s real property asset management plan  states that facility master plans are supposed to be updated every 5 years  to reflect changes in facility condition and mission, but we found that 11 of  20 master plans were out of date and 2 of 20 had not been created yet.
Because EPA makes capital improvement decisions on a site-by-site  basis using master plans that are often outdated, it cannot be assured it is  allocating its funds most appropriately. According to officials responsible  for allocating capital improvement resources, they try to spread these  funds across the agency’s offices and regions equitably but capital  improvement funds have not kept pace with requests. The pressure and  need to effectively share and allocate limited resources among EPA’s  many laboratories were also noted in a 1994 National Academy of Public  Administration report on EPA’s laboratory infrastructure, which found that  EPA has “too many labs in too many locations often without sufficient  resources to sustain a coherent stable program.”
In addition, because decisions regarding laboratory facilities are made  independently of one another, opportunities to improve operating  efficiencies can be lost. Specifically, we found cases where laboratories  that were previously colocated moved into separate space without  considering the potential benefits of remaining colocated. In one case, we  found that the relocation increased some operating costs because the  laboratories then had two facility managers and two security contracts  and associated personnel because of different requirements for the  leased facility. In another case, when two laboratories that were  previously colocated moved into separate new leased laboratories  several miles apart, agency officials said that they did not know to what  extent this move may have resulted in increased operating cost.
EPA also does not have sufficiently complete and reliable data to make  informed decisions for managing its facilities. Since 2003, when GAO first  designated federal real property management as an area of high risk,  agencies have come under increasing pressure to manage their real  property assets more effectively. In February 2004, the President issued  an executive order directing agencies to, among other things, improve the  operational and financial management of their real property inventory.  The order established a Federal Real Property Council within the Office of  Management and Budget (OMB), which has developed guiding principles  for real property asset management. In response to a June 2010  presidential memorandum directing agencies to accelerate efforts to  identify and eliminate excess properties, in July 2010 EPA reported to  the OMB that it does not anticipate the disposal of any of its owned  laboratories and major assets in the near future because these assets are  fully used and considered critical for EPA’s mission.decisions regarding facility disposal are made using the Federal Real  Property Council’s guidance but we found that EPA does not have the  information needed to effectively implement this guidance. Specifically,  EPA does not have accurate, reliable information regarding (1) the need  for facilities, (2) property usage, (3) facility condition, and (4) facility  operating efficiency—thereby undermining the credibility of any decisions  based on this approach.
First, EPA does not maintain accurate data to determine if there is an  agency need for laboratory facilities because many facility master  plans are often out of date. According to EPA’s asset management  plan, the master plans are tools that communicate the link between  mission priorities and facilities. However, without up-to-date master  plans, EPA does not have accurate data to determine if laboratory  facilities are needed for its mission.
Second, the agency does not have accurate data on space needs and  usage because many facility master plans containing space utilization  analyses are out of date. EPA also does not use public and  commercial space usage benchmarks—as recommended by the  Federal Real Property Council—to calculate usage rates for its  laboratories. Instead, EPA measures laboratory usage on the basis of  interviews with local laboratory officials. According to EPA officials,  they do not use benchmarks because the work of the laboratories  varies. In 2008, however, an EPA contractor created a laboratory  benchmark based on those used by comparable facilities at the  Centers for Disease Control and Prevention, the National Institutes of  Health, the Department of Energy, and several research universities  to evaluate space at two ORD laboratories in North Carolina.  Consequently, we believe that objective benchmarks can be  developed for EPA’s unique laboratory requirements. In addition, the  contractor’s analysis concluded that EPA could save $1.68 million in  annual leasing and $800,000 in annual energy costs through  consolidation of the two ORD laboratories. Agency officials told us  they hope to consolidate the laboratories in fiscal year 2012 if funds  are available.
Third, the agency does not have accurate data for assessing facilities’  condition because condition assessments contained in facility master  plans are often outdated. The data may also be unreliable because  data entered by local facility managers are not verified, according to  agency officials. Such verification could involve edit checks or controls  to help ensure the data are entered accurately.
Fourth, EPA does not have reliable operating cost data for its  laboratory enterprise, because the agency’s financial management  system does not track operating costs in sufficient detail to break out  information for individual laboratories or for the laboratory enterprise  as a whole. Reliable operating cost data are important in determining  whether a laboratory facility is operating efficiently, a determination  that should inform both capital investment and property disposal  decisions.
section_title: EPA Does Not Use a Comprehensive Workforce Planning Process for Its Laboratories
paragraphs: EPA does not use a comprehensive planning process for managing its  laboratories’ workforce. For example, we found that not all of the regional  and program offices with laboratories prepared workforce plans as part of  an agencywide planning effort in 2007, and for those that did, most did  not specifically address their laboratories’ workforce. In fact, some  regional management and human resource officials we spoke with were  unaware of the requirement to submit workforce plans to the Office of  Human Resources. Some of these managers told us the program and  regional workforce plans were a paperwork exercise, irrelevant to the way  the workforce is actually managed. Managers in program and regional  offices said that workforce planning for their respective laboratories is  fundamentally driven by the annual budgets of program and regional  offices and ceilings for full-time equivalents (FTE).
In addition, none of the program and regional workforce plans we  reviewed described any effort to work across organizational boundaries to  integrate or coordinate their workforce with the workforces of other EPA  laboratories. For example, although two regional workforce plans  discussed potential vulnerability if highly skilled laboratory personnel  retired, neither plan explored options for sharing resources across  regional boundaries to address potential skill gaps. According to EPA’s  Regional Laboratory System 2009 Annual Report, many of the regional  laboratories provide the same or similar core analytical capabilities— including a full range of routine and specialized chemical and biological  testing of air, water, soil, sediment, tissue, and hazardous waste.  Nonetheless, in these workforce plans, each region independently  determines and attempts to address its individual workforce needs. As a  result, by not exploring options for sharing resources among the ORD,  program, and regional boundaries to address potential skill gaps, EPA  may be missing opportunities to fill critical occupation needs through  resource sharing.
Moreover, EPA does not have basic demographic information on the  number of federal and contract employees currently working in its 37  laboratories. Specifically, EPA does not routinely compile the information  needed to know how many scientific and technical employees it has  working in its laboratories, where they are located, what functions they  perform, or what specialized skills they may have. In addition, the agency  does not have a workload analysis for the laboratories to help determine  the optimal numbers and distribution of staff throughout the enterprise.  We believe that such information is essential for EPA to prepare a  comprehensive laboratory workforce plan to achieve the agency’s mission  with limited resources. Because EPA’s laboratory workforce is managed  separately by 15 independent senior officials, information about that  workforce is tracked separately and is not readily available or routinely  compiled or evaluated. Instead, EPA has relied on ad hoc calls for  information to compile such data.
In response to our prior reports on EPA’s workforce strategy and the  work of the EPA Inspector General, EPA hired a contractor in 2009, in  part to conduct a study to provide information about the agency’s overall  workload, including staffing levels and workload shifts for six major  functions, including scientific research. In its budget justification for fiscal  year 2012, however, the agency reported to Congress that a survey of the  existing workload information provided by the contractor will not  immediately provide information sufficient to determine whether changes  are needed in workforce levels. As of October 2011, EPA had not  released the results of this study, and we therefore cannot comment on  whether its content has implications for the laboratories. The agency  asked its National Advisory Council for Environmental Policy and  Technology to help address scientific and technical competencies as it  develops a new agencywide workforce plan. However, the new plan is not  complete, and therefore it is too early to tell whether the council’s  recommendations will have implications for the laboratories.
Finally, in our July 2011 report on EPA’s laboratory enterprise we  recommended, among other things, that EPA develop a coordinated  planning process for its scientific activities and appoint a top-level official  with authority over all the laboratories, improve physical and real property  planning decisions, and develop a workforce planning process for all  laboratories that reflects current and future needs of laboratory facilities.  In written comments on the report, EPA generally agreed with our findings  and recommendations.
Chairman Harris, Ranking Member Miller, this concludes my prepared  statement. I would be happy to respond to any questions that you or other  members of the subcommittee may have at this time.
section_title: GAO Contact and Staff Acknowledgments
paragraphs: For further information on this statement, please contact David Trimble at  (202) 512-3841 or trimbled@gao.gov. Contact points for our  Congressional Relations and Public Affairs offices may be found on the  last page of this statement. Other staff that made key contributions to this  testimony include Diane LoFaro, Assistant Director; Jamie Meuwissen;  Angela Miles; and Dan Semick.
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