From monitoring air quality and testing drinking water to responding to environmental disasters, the Environmental Protection Agencys (EPA) laboratory enterprise produces scientific research, technical support, and analytical services that underpin many of the policies and regulations the agency implements to protect human health and our nations environment. In the present atmosphere of constrained budgets, EPA, along with its state partners, will need to more effectively use its scientific and laboratory resources and effectively integrate these activities to ensure the agency is best positioned to fulfill its core mission, including responsibilities for responding to a large-scale environmental incident. EPAs laboratory enterprise includes 37 laboratories that are housed in about 170 buildings and facilities located in 30 cities across the nation.
As GAO reported in July 2011, EPA has an uncoordinated approach to managing its laboratory enterpriseincluding the scientific work, workforce, and facilitiesand identified the potential for missed cost-savings opportunities, due in part to fragmentation and overlap of activities. However, GAO was not able to calculate the cost associated with this potential fragmentation and overlapor the corresponding savings from reducing fragmentation and overlapbecause EPA did not have sufficiently complete and reliable operating cost data for its laboratories. EPA also lacked information on the number of federal and contract employees working in its 37 laboratories and the related costs associated with its laboratory workforce. GAOs report found that EPAs uncoordinated approach is due in part to the lack of a top science official with the responsibility or authority to coordinate, oversee, and make management decisions regarding major scientific activities throughout the agencyincluding the work of all 37 laboratories.
EPAs laboratories operate under the direction of 15 different senior officials using 15 different organizational and management structures. EPA has also not fully addressed recommendations from a 1994 independent evaluation by the MITRE Corporation to consolidate and realign its laboratory facilities and workforceeven 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. We found that these problems are evident today and MITREs past recommendations may still be relevant.
Scientific work. EPA does not have a planning process that integrates and coordinates scientific work throughout the agency, including potentially overlapping functions performed by its 37 laboratories. Consequently, 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 EPAs fragmented laboratory enterprise. For example, many of EPAs 10 regional laboratories provide the same or similar types of analytical and technical support functions, such as routine and specialized testing of air samples. In addition, the agencys nine program laboratories provide their respective program offices with research and analytical services that may overlap with research and development performed by the Office of Research and Developments (ORD) 18 laboratories. For example, an Office of Air and Radiation program laboratory located in Michigan does emissions testing, while a separate ORD laboratory located in North Carolina does emissions testing research.
In addition to potential overlap in the work performed by these two laboratories, the fragmentation across the laboratory enterprise may fail to provide the agency with opportunities for laboratories to share subject matter expertise and scientific equipment. For example, both the Office of Air and Radiation and ORD laboratories utilize the same kind of specialized equipment, called truck dynamometers, yet each separately requested funding in fiscal years 2010 and 2011 that totaled over $4 million to expand or modify their facilities for emissions testing. While the agency funded only one of the two potentially duplicative requests, the net result is that the second laboratorys facility and equipment needs were not met. In addition to potential lost opportunities to share facilities and equipment, the agency may also be missing opportunities to share expertise, such as technical knowledge pertaining to the use of specialized equipment.
In addition, to support the implementation of both state and federal environmental statutes, various state agencies and public universities operate over 70 separate environmental laboratories (see fig. below) that may perform functions similar to those performed by EPA laboratories. Similar to the work of some EPA regional laboratories, state environmental laboratories conduct regular testing of air, water, soil, food, and other media for signs of contamination. State laboratories also perform analytical and method development functions that may be similar to those performed by ORD laboratories. EPA has partnered with some state laboratories for specific programs, but to fully leverage these state scientific resources EPA will first need to integrate and coordinate the activities of its own laboratories agencywide.
Potential Overlap among Federal and State Environmental Laboratories
Workforce. EPA does not use a comprehensive planning process for managing its laboratories workforce and may be missing opportunities to work across organizational boundaries to integrate, share, or coordinate laboratory workforces that perform potentially overlapping functions. For example, many of the 10 regional laboratories provide the same or similar core analytical capabilitiesincluding a full range of routine and specialized chemical and biological testing of air, water, soil, sediment, tissue, and hazardous wastebut each region independently determines and attempts to address its individual workforce needs. EPA also lacks basic demographic 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. GAO believes that such information is essential for EPA to prepare a comprehensive laboratory workforce plan to achieve the agencys mission with limited resources.
Facilities. EPA manages its laboratory facilities in a way that may fail to achieve operating efficiencies that could be gained by colocating laboratories with overlapping activities and facility needs. EPA manages laboratories on a site-by-site basis and does not make capital improvement or other decisions for each site in the context of all the agencys laboratory properties. Because decisions regarding laboratory facilities are made independently of one another, opportunities to improve operating efficiencies can be lost. For example, GAO found cases where laboratories that were previously colocated moved into separate space without considering the potential benefits of remaining colocated. In one case, GAO 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.Moreover, EPA lacks sufficiently complete and reliable data to make informed decisions for managing its laboratory facilities. Among other things, EPA lacks reliable information on laboratory usage, which is needed to inform both capital investment and property disposal decisions. For example, EPA does not have reliable data on space utilization because its data are either out of date or not based on objective criteria such as public and commercial space usage benchmarks. Instead, EPA measures laboratory usage on the basis of subjective interviews with local laboratory officials.
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).
The four national program offices that operate laboratories are the Office of Air and Radiation, the Office of Enforcement and Compliance Assurance, the Office of Chemical Safety and Pollution Prevention, and the Office of Solid Waste and Emergency Response.
To improve cohesion and efficiency in the management and operation of EPAs laboratories, GAO recommended in July 2011 that the Administrator of EPA
To address potentially overlapping laboratory activities and achieve efficiencies by sharing workforce expertise, GAO recommended in July 2011 that the Administrator of EPA
To identify opportunities to reduce costs associated with maintaining a footprint of 170 laboratory buildings and facilities that support organizations with potentially overlapping functions, facility, and equipment needs, GAO recommended in July 2011 that the Administrator of EPA
The information contained in this analysis is based on findings from the products listed in the related GAO products section. Information regarding state environmental laboratories is based on analysis of a May 2011 Environmental Council of States Green Report, a 2007 report on the capability and capacity of state environmental laboratories conducted by the Association of Public Health Laboratories, and information obtained from state environmental laboratory websites and EPAs Environmental Response Laboratory Network website.
GAO provided a draft of its July 2011 report to EPA for review and comment. EPA generally agreed with GAOs recommendations. In November 2011, EPA noted that current efforts to reduce the federal budget deficit require EPA to more effectively use its laboratory enterprise to help ensure that its scientific activities respond to the agencys highest-priority needs. The agency also acknowledged the demand for sharing facilities and equipment, as well as expertise and human resources. EPA agreed that it should (1) include alternate approaches for organizing the laboratory workforce and infrastructure in any future studies of its laboratories, such as the long-term study for which the agency requested $2 million in the Presidents fiscal year 2012 budget; (2) develop an overarching planning process that better reflects the collective goals, objectives, and priorities of its laboratories; (3) develop a comprehensive workforce-planning process for its laboratories; (4) improve physical infrastructure and real property planning and investment decisions by managing laboratory facilities as part of an interrelated portfolio of facilities; (5) maintain up-to-date master plans that include objective benchmarks; and (6) improve the completeness and reliability of operating cost and other data needed to manage its real property.
In response to our recommendation to establish a top-level science official with the authority and responsibility to coordinate, oversee, and make management decisions regarding major scientific activities throughout the agency, EPA proposed to increase the responsibilities of its science advisor. However, it is not clear that this will fully address the issue and it may ultimately introduce additional challenges for EPA. We note that in 2000, the National Research Council reported no single individual could reasonably be expected to direct a world-class research program in ORD while also trying to improve scientific practices and performance throughout the rest of the agency, stating that these jobs are inherently different. The Council cautioned that assigning agency-wide scientific authority to the assistant administrator for ORD might produce a conflict of responsibilities, because many decisions about science in the regulatory programs could affect ORDs budget or favor ORDs research over research done elsewhere. EPA managers need to ensure that there is sustained attention on these issues in order to assure its efforts are carried out and achieve the intended results.
GAO also provided a draft of new information included in this report section that was not previously reported in the July 2011 report, such as information pertaining to state environmental laboratories, to EPA for review and comment. EPA provided technical comments, which were incorporated as appropriate.
As part of its routine audit work, GAO will track the extent to which progress has been made to address the identified actions and report to Congress.
For additional information about this area, contact David C. Trimble at (202) 512-3841 or email@example.com.