EPA Chemical Reviews: Workforce Planning Gaps Contributed to Missed Deadlines
Fast Facts
In 2016, Congress set deadlines for the Environmental Protection Agency to review health and environmental impacts of certain chemicals already in use, starting initially with 10 chemicals. It also required EPA to determine the safety of certain new chemicals before they can be manufactured.
We found that EPA:
- Missed most deadlines for reviews of existing chemicals since 2016
- Typically met the deadline less than 10% of the time for completed pre-manufacture reviews from 2017-2022
EPA struggled to recruit and develop the workforce needed for this work. We recommended that EPA develop a process and timeline to improve its workforce planning.
Highlights
What GAO Found
Since 2016, the Environmental Protection Agency (EPA) has missed most deadlines for reviewing existing and new chemicals under the Toxic Substances Control Act (TSCA), as amended. Once prioritized, existing chemicals are reviewed in two main phases —risk evaluation and risk management—and TSCA established specific deadlines for each phase. GAO found that EPA completed the first risk evaluation step (i.e., scoping) for the initial 10 existing chemical reviews on time. However, EPA missed all but one subsequent risk evaluation and risk management deadlines for these chemicals. Additionally, TSCA as amended provides that a person may only manufacture a new chemical if such person submits information to EPA and the agency makes an affirmative determination on the risk of injury to health or the environment. However, GAO found that among those pre-manufacture reviews that EPA completed from 2017 through 2022, the agency typically completed the reviews within the 90-day TSCA review period less than 10 percent of the time. EPA missed the chemical review deadlines due in part to several contributing factors and is implementing some related improvements (e.g., modernizing information systems). However, according to EPA, resource constraints, including insufficient staff capacity, remain the primary reason for missed chemical review deadlines.
EPA has engaged in some initial workforce planning activities for its chemical review responsibilities, but significant workforce planning gaps contribute to missed chemical review deadlines. For example, in March 2021, EPA conducted a skills gap assessment, which included hiring targets for mission-critical occupations. However, EPA officials told GAO the assessment no longer reflects current workforce needs, and that EPA has not created a strategic workforce plan to develop long-term strategies for recruiting, developing, and retaining staff. GAO has identified five principles with which federal agencies' strategic workforce planning efforts should align (see figure). EPA officials told GAO that while they agree that these principles are relevant and reasonable for its TSCA workforce planning efforts, they have not developed a process or timeline to fully align such efforts with these principles. Without doing so, EPA will likely continue to struggle to recruit, develop, and retain the workforce it needs to meet TSCA deadlines for completing existing and new chemical reviews.
Figure: GAO's Five Key Strategic Workforce Planning Principles
Why GAO Did This Study
Thousands of chemical substances play an important role in modern life and commerce, but can also present serious risks to human health and the environment. In 2016, Congress amended TSCA to establish new deadlines for reviewing chemicals already in commerce, including an initial set of 10 existing chemicals. It also provided that EPA make a formal determination before new chemicals can be manufactured.
GAO was asked to review EPA's implementation of its chemical review responsibilities under TSCA. This report evaluates the extent to which (1) EPA met selected TSCA deadlines for reviewing existing and new chemicals since June 2016, and (2) EPA engaged in workforce planning for implementing its chemical review responsibilities. GAO reviewed relevant laws, regulations, and workforce planning documents, and collected EPA data on new chemical review times and its workforce. GAO also interviewed EPA officials and representatives from industry and environmental health stakeholder organizations.
Recommendations
GAO recommends that EPA develop a process and timeline to fully align its workforce planning efforts for implementing its TSCA chemical review responsibilities with workforce planning principles. EPA agreed with our recommendation but indicated that insufficiency of resources is the primary factor, among others we noted, for missed deadlines.
Recommendations for Executive Action
| Agency Affected | Recommendation | Status |
|---|---|---|
| Environmental Protection Agency | The Administrator of EPA should direct the Assistant Administrator of OCSPP to develop a process and timeline to fully align its workforce planning efforts for implementing EPA's TSCA chemical review responsibilities with workforce planning principles and incorporate the results, as appropriate, into EPA's annual plan for chemical risk evaluations under TSCA. (Recommendation 1) |
As of July 2025, we have updated this status with the latest information that EPA provided to us and are awaiting resolution on the agency's workforce plans. This recommendation is partially implemented. In January 2025, EPA officials from the Office of Chemical Safety and Pollution Prevention (OCSPP) demonstrated steps the office had taken to align its workforce planning efforts for implementing TSCA chemical review responsibilities with key principles and incorporating the results into its annual plan, as appropriate. These efforts included completing: (1) an agencywide Fiscal Year 2025-2028 EPA Succession Management Plan, developed with EPA's Office of Mission Support; (2) the FY23 Workforce Analysis and Development Plan; (3) a Hiring Standard Operating Procedure, scheduled for implementation by the end of the second quarter of FY 2025, and evaluation after six months to identify potential lags and implement countermeasures; and (4) its 2025 Annual Plan for Chemical Risk Evaluations under TSCA. In particular, the annual plan identified resources necessary to complete the risk evaluations it described. According to EPA, the FY23 Workforce Analysis and Development Plan was based on interviews with leaders and managers across OCSPP's offices and surveys of bargaining unit employees to help the office establish a hiring and employee retention approach. Additionally, In February 2024, OCSPP developed a Workforce Action Plan with related follow-on goals to address hiring delays and retention challenges, and to summarize its planning activities on an annual basis. OCSPP completed one of these goals in February 2025, when the office finalized its recruitment and hiring standard operating procedure, which will also serve as a training tool. EPA also included elements of the workforce planning principles in its 2025 annual plan for chemical risk evaluations under TSCA. For example, the annual plan highlighted a technical document that reviewed EPA's anticipated workload for fiscal years 2024, 2025, and 2026 and updates to TSCA activities and resources. While experiencing cuts to OCSPP's budget in fiscal year 2024, EPA continues to focus on opportunities to create efficiency, according to the 2025 annual plan. By taking these steps, OCSPP can better align its workforce needs with its TSCA responsibilities. In June 2025, OCSPP informed GAO that this recommendation has not been fully implemented and likely will not be until EPA addresses February 2025 OMB/OPM guidance on agency reduction in force and reorganization plans.
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