Environmental Protection Agency Standards of Employee Conduct Need Improvement

FPCD-79-48: Published: May 8, 1979. Publicly Released: May 8, 1979.

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An evaluation of the standards of conduct for Environmental Protection Agency (EPA) employees indicated that the following issues were not being adequately addressed: outside employment, acceptance of an honorarium, negotiations for employment, and acceptance of gifts. The standards reviewed were conflict of interest matters of a financial nature, non-Government employment situations, and other dealings with parties outside EPA.

Standards of conduct were not effectively implemented at EPA. It was found that employees were not always aware of their responsibilities. Employees were provided with inconsistent advice on questions of ethics because deputy counselors interpret and apply the standards independently. The system for implementing standards of conduct at EPA results in inconsistencies because the standards are interpreted by 49 deputy counselors with only minimal central guidance or review. Sources of information that can be used to evaluate the adequacy of EPA standards of conduct were available, but had not been used for this purpose. These databases could be tabulated in a usable format and, through analysis by the EPA counselor or under his direction, could be used to determine the needed changes to the standards of conduct or to determine additional guidance needed because of specific problems confronting EPA employees.

Recommendation for Executive Action

  1. Status: Closed

    Comments: Please call 202/512-6100 for additional information.

    Recommendation: The Administrator, EPA, should request the EPA Counselor to oversee the preparation of a package that includes all the pertinent EPA documents relating to employee ethical conduct, have the personnel officer provide the package to all newly hired employees, and establish a procedure for emphasizing the importance of standards of conduct during new employee orientation. In addition, the Inspector's Office should supplement the film presentation with additional information to cover all segments of the Standards of Conduct regulation. The Administrator should have the EPA Counselor: (1) develop guidance for use by deputy counselors in applying the standards of conduct; (2) develop criteria for applying various resolutions to conflict of interest problems; and (3) establish a procedure for regularly communicating with deputy counselors to ensure consistent application of the standards. The Administrator should designate the Inspector General as the focal point for identifying information sources that can be used to evaluate the adequacy of EPA standards of conduct. The Administrator should then require a periodic evaluation of the effectiveness of the standards of conduct with recommendations for improvement directed to the EPA Counselor.

    Agency Affected:


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