On April 20, 2023, the U.S. Government Accountability Office (GAO) issued its updated High Risk List, which highlights 37 areas across the federal government that are vulnerable to waste, fraud, abuse, and mismanagement, or that need broad reform. The High Risk List includes “Transforming EPA’s Process for Assessing and Controlling Toxic Chemicals.” GAO states that the U.S. Environmental Protection Agency’s (EPA) ability to implement its mission of protecting public health and the environment effectively depends on its assessing the risks posed by chemicals in commerce and those that have yet to enter commerce in a credible and timely manner. EPA supports the evaluation of such risks through its Integrated Risk Information System (IRIS) and by implementing the Toxic Substances Control Act (TSCA). According to GAO, because EPA had not developed sufficient chemical assessment and risk information under these programs to limit exposure to many chemicals that may pose substantial health risks, GAO added this issue to the High-Risk List in 2009. GAO reports that overall ratings for four criteria -- leadership commitment, capacity, action plan, and demonstrated progress -- remain unchanged since 2021. The overall rating for monitoring increased to partially met. For IRIS, leadership commitment, monitoring, and demonstrated progress increased to partially met. For TSCA, leadership commitment increased to met, and action plan and monitoring increased to partially met. GAO notes that as of February 2023, five recommendations related to the management of toxic chemicals remain open, such as:

• Periodically assessing the demand for chemical assessments and the resources needed to produce IRIS assessments; and

• Developing a process and timeline to ensure EPA’s workforce planning efforts fully align with relevant planning principles and incorporating the results, as appropriate, into EPA’s annual plan for chemical risk evaluations under TSCA. According to GAO, this will help ensure EPA can effectively implement its TSCA review responsibilities. In February 2023, GAO reported that strategic workforce planning is essential in helping agencies align their workforces with their current and emerging missions and that it also helps them develop long-term strategies for recruiting, developing, and retaining staff. More information on GAO’s February 2023 report is available in our February 24, 2023, memorandum.

GAO states that continued congressional oversight of EPA’s workforce planning efforts is needed to help ensure EPA identifies the resources it needs to assess and control toxic chemicals. According to GAO, this area has realized more than ten benefits since it was added to the High-Risk List in 2009, including:

• The IRIS Program increased its coordination with other EPA offices and external federal entities. This will help ensure the offices avoid duplicative work on chemical assessments, can assist each other with obtaining chemical data, and use many of the same chemical evaluation tools and techniques for greater consistency in final products; and

• The Office of Pollution Prevention and Toxics (OPPT) completed a skills gap assessment in March 2021 that included hiring targets and anticipated attrition counts for various years. This helped EPA better understand its future workforce needs for implementing TSCA and informed its budget request for fiscal year 2023.