Environmental Protection:

EPA Needs to Ensure That Best Practices and Procedures Are Followed When Making Further Changes to Its Library Network

GAO-08-304: Published: Feb 29, 2008. Publicly Released: Mar 13, 2008.

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Established in 1971, the Environmental Protection Agency's (EPA) library network provides staff and the public with access to environmental information. Its 26 libraries contain a wide range of information and resources and are located at headquarters, regional offices, research centers, and laboratories nationwide. In 2006, EPA issued a plan to reorganize the network beginning in fiscal year 2007. The plan proposed closing libraries and dispersing, disposing of, and digitizing library materials. GAO was asked to assess (1) the status of, and plans for, the network reorganization; (2) EPA's rationale for reorganizing the network; (3) the extent to which EPA has communicated with and solicited the views of EPA staff and external stakeholders in conducting the reorganization; (4) EPA's steps to maintain the quality of library services after the reorganization; and (5) how EPA is funding the network and its reorganization. For this study, GAO reviewed pertinent EPA documents and interviewed EPA officials and staff from each of the libraries.

Since 2006, EPA has implemented its reorganization plan to close physical access to 4 libraries. In the same period, 6 other libraries in the network decided to change their operations, while 16 have not changed. Some of these libraries have also digitized, dispersed, or disposed of their materials. Since the reorganization, EPA has begun drafting a common set of agencywide library procedures and has hired a program manager for the network. While these procedures are under development, however, EPA has imposed a moratorium on further changes to the network in response to congressional and other expressions of concern. EPA's primary rationale for the library network reorganization was to generate cost savings by creating a more coordinated library network and increasing the electronic delivery of services. However, EPA did not fully follow procedures recommended in a 2004 EPA study of steps that should be taken to prepare for a reorganization. In particular, EPA did not fully evaluate alternative models, and associated costs and benefits, of library services. EPA officials stated that they needed to act quickly to reorganize the library network in response to a proposed fiscal year 2007 funding reduction. EPA did not develop procedures to inform staff and the public on the final configuration of the library network, and EPA libraries varied considerably and were limited in the extent to which they communicated with and solicited views from stakeholders before and during the reorganization effort. In particular, EPA's plan did not include information that the Chemical Library was to close, and EPA did not inform staff or the public until after the fact. EPA's communication procedures were limited or inconsistent because EPA acted quickly to make changes in response to a proposed fiscal year 2007 funding reduction, and because of the decentralized nature of the library network. EPA is currently increasing its communication efforts. EPA does not have a post-reorganization strategy to ensure the continuity of library services and has not yet determined the full effect of the reorganization on library services. Moreover, EPA has recently made several changes that could have impaired user access to library materials and services. For example, EPA did not determine whether federal property management regulations applied to the dispersal and disposal of library materials before it closed the libraries. Furthermore, EPA lacked oversight of the reorganization process and does not have procedures that would allow the agency to measure performance and monitor user needs. Several different EPA offices are responsible for the libraries in the network. Each office generally decides how much funding to allocate to the libraries for which it is responsible and how to fund their reorganization. However, when faced with a proposed budget reduction of $2 million in fiscal year 2007, EPA specifically directed that these offices reduce funding for their libraries and did not specify how to achieve the reduction. Additional funds were not allocated to assist offices in closing their libraries.

Status Legend:

More Info
  • Review Pending-GAO has not yet assessed implementation status.
  • Open-Actions to satisfy the intent of the recommendation have not been taken or are being planned, or actions that partially satisfy the intent of the recommendation have been taken.
  • Closed-implemented-Actions that satisfy the intent of the recommendation have been taken.
  • Closed-not implemented-While the intent of the recommendation has not been satisfied, time or circumstances have rendered the recommendation invalid.
    • Review Pending
    • Open
    • Closed - implemented
    • Closed - not implemented

    Recommendations for Executive Action

    Recommendation: To ensure that critical library services are provided to EPA staff and other users, the Administrator of EPA should continue the agency's moratorium on changes to the library network until the agency incorporates and makes public a plan that includes a process that (1) ensures sufficient oversight and control over the reorganization process, (2) continuously and consistently monitors the impact of the reorganization on EPA staff and the public, and (3) takes corrective actions as necessary to provide the continued delivery of services.

    Agency Affected: Environmental Protection Agency

    Status: Closed - Implemented

    Comments: To provide oversight of the reorganization process and ensure sufficient monitoring, and continuous improvement of the Library Network, EPA has implemented a process that requires the review of library policy and procedures every three years. To keep library managers and staff engaged in improving library operations, among other things, the national library program manager holds monthly network teleconferences with library managers and staff on matters of interest to the entire network or on operational topics, such as the library policy and procedures. EPA's Library Network Policy and Procedures are publicly available on its website and guidance is posted on the Network's Intranet site. In addition, the Library Network Annual Meeting, held in April 2012, included a session on policy and procedures. The Library Network has also developed and implemented multiple feedback mechanisms using a variety of communication channels to gather feedback from library users and stakeholders, including an agencywide information needs assessment, a centralized customer feedback form, and a dedicated email address to gather feedback from EPA customers, concerned stakeholders, and the general public.

    Recommendation: To ensure that critical library services are provided to EPA staff and other users, the Administrator of EPA should continue the agency's moratorium on changes to the library network until the agency incorporates and makes public a plan that includes improving its outreach efforts by developing a process that (1) informs stakeholders of the final configuration of the library network, and the implementation goals and timeline to achieve this configuration; (2) communicates information to stakeholders early, often, and consistently across all libraries, and solicits the views of EPA staff and external stakeholders; and (3) obtains the views of industry experts to determine leading practices for library services.

    Agency Affected: Environmental Protection Agency

    Status: Closed - Implemented

    Comments: As we reported in September 2010 (GAO-10-947), EPA has taken steps to communicate with staff and other stakeholders about its library network including providing information about the libraries as well as soliciting information from library users. In general, EPA staff and external stakeholders told us the agency is doing a better job of communicating with them and soliciting input on the operations and future direction of the library network, particularly at the local level. To keep library managers and staff engaged in improving library operations, EPA has adopted a number of techniques to communicate with them and solicit their input. These techniques have allowed EPA to gather staff input for policies and procedures, operational issues, and Web page improvements. Examples include the following: The national library program manager holds monthly network teleconferences with library managers and staff on matters of interest to the entire network or on operational topics, such as the library policy and procedures. The national library program manager also holds ad hoc teleconferences with library managers elsewhere in the network to discuss their libraries needs. Managers and staff use mailing lists to communicate with one another about daily library operations or requests for assistance. EPA also holds annual network meeting in different locations for library managers and staff to foster collaboration, provide training, and share information about the network. At the October 2009 meeting, participants discussed ways to address results of the 2009 staff survey, prepared for the next round of digitization, and discussed ways to improve library services.

    Recommendation: To ensure that critical library services are provided to EPA staff and other users, the Administrator of EPA should continue the agency's moratorium on changes to the library network until the agency incorporates and makes public a plan that includes developing a strategy to justify its reorganization plans by (1) evaluating and determining user needs for library services; (2) taking an inventory of EPA information resources and determining the extent to which these resources are used; (3) evaluating technological factors, such as digitization procedures and integration of online databases, to ensure an optimal level of services; (4) evaluating and conducting a benefit-cost assessment for each alternative approach for the network, including the approach that existed before the reorganization; and (5) reviewing and revising, as appropriate, the existing policy and procedures that guide the library network.

    Agency Affected: Environmental Protection Agency

    Status: Closed - Implemented

    Comments: EPA's current library procedures require libraries to perform an inventory of its collections on a regular basis, update the catalog records accordingly, and to collect statistics on the services they provide and the usage of library materials, including print materials in the library and electronic resources available online. In addition, EPA surveyed library users in 2009 to evaluate and determine user needs for library services. The goals of the assessment included evaluating how EPA staff use library services, determining what library services are most critical to customers, and what additional library services and/or resources are needed. EPA is using the results of the assessment to plan effective library services that meet user needs. For example, based on input from users and librarians, along with usage data, EPA has (1) increased electronic journals subscriptions on the EPA Desktop Library from approximately 2,000 titles to over 5,400, (2) enhanced the search capabilities on EPA websites, (3) offers training on how to use the library resources and services, and (4) provides remote access to offsite users. EPA has also made improvements to the agency's digitization procedures and the user interface for the digital archive. Over 40,000 electronic documents are now available in EPA's environmental publications archive; and efforts continue to ensure that all digital documents are linked to EPA's online catalog records. To ensure that EPA's existing policies and procedures remain current, EPA's processes require review of policy and procedures every three years.

    Recommendation: To ensure that critical library services are provided to EPA staff and other users, the Administrator of EPA should continue the agency's moratorium on changes to the library network until the agency incorporates and makes public a plan that includes implementing procedures that ensure that library materials are dispersed and disposed of consistently and in accordance with federal property management regulations.

    Agency Affected: Environmental Protection Agency

    Status: Closed - Implemented

    Comments: On March 4, 2011, EPA's Chief Information Officer issued Library Materials Dispersal Procedures. The stated purpose of the document was to establish Agency-wide procedures, by which libraries in the EPA National Library Network retain, reduce, disperse or dispose of their library contents when appropriate. In November 2011, EPA's Library Network updated guidance developed in 2009 to assist library staff with the appropriate dispersal of materials. EPA's procedures for dispersal of library materials are available on the agency's intranet site and have been shared with the Library Network staff.

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