The Government Accountability Office (GAO) says the Environmental Protection Agency (EPA) should develop a formal “lessons learned” process to improve hazardous waste removal following disasters.
To remove household hazardous waste—some items that can catch fire, react, or explode under certain circumstances or that are corrosive or toxic—after the 2018 and 2020 California wildfires, EPA took steps that followed its emergency response policy. For example, EPA led coordination efforts between federal, state, and local agencies and established incident management teams. These teams developed plans for assessment, removal, transportation, and disposal of the waste. EPA removed waste from three counties in 2018 and seven counties in 2020.
Following its wildfire responses, EPA conducted lessons learned activities, such as gathering feedback from staff to identify lessons and developing corrective actions. Lessons learned provide a method to share good ideas for improving work processes, quality, and cost-effectiveness. Key practices of a lessons learned process include collecting and sharing information on positive and negative experiences and developing and tracking corrective actions.
However, GAO identified additional lessons learned activities that may have been useful. For example, GAO found that EPA does not track corrective actions in a formal, centralized way, and EPA has not implemented all of the needed corrective actions. After the 2018 wildfires, for example, EPA found that it needed to develop a proposal to increase the number of EPA On-Scene Coordinators responsible for overseeing disaster responses, but the agency did not do so.
EPA conducts lessons learned activities on a case-by-case basis and does not have a formal lessons learned process in place for wildfire or other disaster responses that specifies when and what lessons learned activities should be conducted. The National Response Framework—which describes how the federal government, states, and others should respond to disasters and emergencies—states that planning for disaster response should include a feedback loop, including through lessons learned processes. Developing a formal lessons learned process that includes key practices, such as tracking corrective actions, will help EPA be better prepared to respond to future disasters, including those that involve removing household hazardous waste.
EPA concurred with GAO’s recommendation to develop a lesson learned process. The agency said however that the report draws broad national conclusions from a limited set of regional findings.