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EPA Chemical Reviews: Workforce Planning Gaps Contributed to Missed Deadlines

GAO-23-105728 Published: Feb 17, 2023. Publicly Released: Feb 23, 2023.
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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.

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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

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.


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)
EPA agreed with our recommendation in February 2023. In August 2023, EPA responded to us indicating that OCSPP plans to align its TSCA workforce planning efforts with relevant principles through (1) a workforce analysis to be completed in January 2024, and (2) a succession management plan to be completed by late 2023, and a follow-up succession plan in March 2024. These two concurrent efforts are planned as follows: (1) OCSPP will hire external consultants to conduct an analysis of the office's current workforce that will involve OCSPP management and employees to develop an analytical report that compares the organizations' s current workforce composition and skills to the capabilities need to achieve programmatic results. EPA intends the analysis to identify areas for improvement and make recommendations for strengthening OCSPP's workforce. EPA noted that engaging outside experts will help OCSPP build the administrative, educational, and other capabilities needed to support workforce planning. (2) EPA's Office of Mission Support is developing an agency-wide succession management plan to identify mission-critical positions that are vulnerable to turnover as a result of retirement, internal factors (e.g., resource allocations), or external market forces (e.g., Administration priorities). This succession management plan is also intended to address gaps in mission-critical positions by cultivating employees with the potential and desire to assume those duties and responsibilities in the present and future. After the conclusion of both efforts, EPA plans to monitor and evaluate progress by conducting periodic follow-up assessments. EPA expects to complete the first follow-up workforce analysis assessment in January 2024 and the first follow-up succession plan assessment in March 2024. EPA also indicated that, in March 2023, OCSPP was cleared to use Title 42 hiring authority to attract and appoint up to 25 individuals in mission-critical positions (e.g., scientists and engineers); the office strives to fill at least one of the 25 positions before the end of 2023.

Full Report

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Agency evaluationsChemical safetyChemicalsLabor forceRisk assessmentRisk managementToxic substancesWorkforce planningEnvironmental protection