Enclosed are the Office of Inspector General’s (OIG’s) three fiscal year 2015 management challenges and one internal control weakness for consideration as part of the U.S. Chemical Safety and Hazard Investigation Board (CSB) Federal Managers’ Financial Integrity Act review. The Reports Consolidation Act of 2000 requires our office to report what we consider the most serious management and performance challenges facing CSB. We used to audit and investigative work, public hearings, CSB board meetings, and additional analysis of CSB operations to arrive at the issues presented. We previously provided you a draft of this documentation, and we considered your comments in finalizing these management challenges and the internal control weakness.
Challenge: CSB Should Address Employee Morale
- A toxic work environment resulted in the departure of at least nine experienced CSB employees (almost 25 percent of its staff).
- Current and former CSB employees indicated that the former Chairperson retaliated against whistleblowers, resulting in employees fearing retaliation.
- The former Chairperson’s disregard for proper board governance processes caused CSB employees and fellow board members consternation, leading to an unproductive work environment.
Challenge: CSB Should Increase Its Investigations and Improve Investigative Management Controls
CSB is not investigating all accidents that fall within its legal jurisdiction and should increase the number of investigations it conducts. Pursuant to its enabling statute, the Clean Air Act Amendments of 1990, 42 U.S. Code § 7412(r) (6), CSB “shall … investigate (or cause to be investigated), determine, and report to the public in writing the facts, conditions, and circumstances, and the cause or probable cause, of any accidental chemical release resulting in a fatality, serious injury, or substantial property damages.” Further, CSB needs to improve controls over the investigations that it does conduct. CSB believes it is operating according to its statutory mandate and cites a lack of resources to investigate the additional accidents cited.
Challenge: CSB Should Determine the Need for a Chemical Reporting Regulation
CSB has not published a chemical incident reporting regulation as envisioned in the Clean Air Act Amendments of 1990. In 2008, the U.S. Government Accountability Office (GAO) recommended that CSB publishes a regulation requiring facilities to report all chemical accidents. In 2009, CSB notified the public of a proposed reporting regulation. CSB has not yet published the regulation.
Internal Control Weakness: CSB Should Address Operational Controls
CSB has several operational controls that should be addressed to ensure its administrative operations are working in concert with its mission. These controls relate to purchase cards, program operation, the information security program, and electronic records management.
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