Where We Can Improve

EPA regularly tracks whether we are on schedule to get out about 30 important EPA regulations and guidance documents. Getting these out on schedule is important for at least three reasons:

• The sooner we get them out the sooner their implementation starts better protecting human health and the environment.
• It affects the overall reputation of the agency. Being on time shows you have your act together.
• Staying on time also means we don’t 'jam' the end of the process if we need to meet a court-ordered deadline. Rushing final reviews and analyses results in a lower quality product.

How are we doing? On average we are almost 70 days behind schedule (see graph below). That’s not very good.

We're asking questions about why this is happening. It turns out a minority of the actions account for a large amount of the delay. Ever hear of Pareto's Principle or the "80/20 Rule"? That is, about 80 percent of an effect will come from about 20 percent of the causes. In this case, 76 percent of the delay is being caused by about 19 percent of the actions we are tracking.

Consequently, we are focusing more attention on the few rules/guidances that are causing the most delay. So far we’ve found no easy ways to get any of them back on schedule. For instance, with one rule, the Department of Justice suggested a raft of changes that made it more legally defensible, so we needed to take the time to make the changes and get the rule re-reviewed.

While I think we can speed up some rules, part of what we are learning is that we may need to be more realistic about how quickly things can be done on certain rules. The trick may be to figure out which particular rules may need more time and build that into the schedules from the start.