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Any Open Recommendations
Reports
Audit of GSA’s Response to COVID-19: PBS Faces Challenges to Ensure Water Quality in GSA-Controlled Facilities
We recommend that the PBS Commissioner provide appropriate oversight to ensure water is safe to occupants in its buildings by defining roles and responsibilities for maintaining water quality in GSA-controlled facilities.
We recommend that the PBS Commissioner provide appropriate oversight to ensure water is safe to occupants in its buildings by ensuring that: water quality is maintained through consistent policies and practices nationwide; deviations to PBS’s Drinking Water Quality Management policy and the PBS water safety guidance are approved by PBS’s Central Office; and any water safety policies or guidance developed by regional offices do not contradict policies and guidance issued at the national level.
We recommend that the PBS Commissioner provide appropriate oversight to ensure water is safe to occupants in its buildings by ensuring that PBS’s water safety activities are incorporated into O&M contracts, recorded in PBS’s National Computerized Maintenance Management System, and overseen by PBS personnel.
We recommend that the PBS Commissioner provide appropriate oversight to ensure water is safe to occupants in its buildings by incorporating PBS’s water safety oversight responsibilities into quality assurance surveillance plans for O&M contracts to ensure contractor compliance with water safety activities.
We recommend that the PBS Commissioner provide appropriate oversight to ensure water is safe to occupants in its buildings by ensuring that PBS personnel and O&M contractors have access to tenant spaces so flushing can be performed.
We recommend that the PBS Commissioner provide appropriate oversight to ensure water is safe to occupants in its buildings by amending O&M and other contracts to ensure that energy efficiency and water conservation requirements do not conflict with PBS’s Drinking Water Quality Management policy and the PBS water safety guidance.
We recommend that the PBS Commissioner provide appropriate oversight to ensure water is safe to occupants in its buildings by ensuring that water is tested in GSA’s child care centers as required by PBS’s Drinking Water Quality Management policy.
We recommend that the PBS Commissioner provide appropriate oversight to ensure water is safe to occupants in its buildings by ensuring water quality test results—especially those above EPA action levels—are communicated timely to building tenants, GSA child care center operators, and parents and guardians of affected children.
We recommend that the PBS Commissioner provide appropriate oversight to ensure water is safe to occupants in its buildings by amending and implementing PBS’s Drinking Water Quality Management policy to: include reduced occupancy or decreased water usage as additional criteria for lead, copper, Legionella bacteria, and other contaminant testing; ensure requirements in PBS’s Drinking Water Quality Management policy, its companion Desk Guide for Drinking Water Quality Management, and the PBS water safety guidance are incorporated into the amended policy, unless there are safety reasons why such requirements cannot or should not be incorporated; and formalize its requirement to complete additional testing at child care centers that close for extended periods of time.
Audit of GSA’s Response to COVID-19: PBS Faces Challenges to Meet the Ventilation and Acceptable Indoor Air Quality Standard in GSA-Owned Buildings
We recommend that the PBS Commissioner complete a comprehensive assessment to determine whether GSA-owned building air handlers meet the ASHRAE ventilation standard’s minimum outdoor air requirements and develop a comprehensive plan to address deficiencies identified.
We recommend that the PBS Commissioner create and implement a plan to notify building occupants whenever deficiencies and hazards associated with outdoor air requirements are identified.
We recommend that the PBS Commissioner ensure that all PBS staff with ventilation system responsibilities, including contracting officer’s representatives, contracting officers, project managers, and building managers, are trained on the requirements of the ASHRAE ventilation standard.
We recommend that the PBS Commissioner ensure operations and maintenance contracts define requirements for regular testing, adjusting, and balancing of air handlers.
We recommend that the PBS Commissioner ensure that GSA’s Guidance for COVID-19 HVAC Operations adheres to CDC COVID-19 guidance for improved building ventilation.
COVID-19: PBS Faces Challenges in Its Efforts to Improve Air Filtration in GSA-Controlled Facilities
We recommend that the PBS Commissioner for GSA-owned facilities: a. Conduct an accurate and complete assessment of HVAC systems to identify deficiencies in air filtration. Based upon the assessment, PBS should maximize central air filtration in existing HVAC systems without significantly reducing design airflow; b. Review and update current and future operations and maintenance contracts to ensure that they clearly identify the required MERV air filters and preventive maintenance schedules; c. Establish controls to ensure that PBS obtains and maintains complete preventive maintenance records; and d. Ensure that contracting officer representatives conduct inspections of mechanical rooms and preventive maintenance records to ensure that air filters meet MERV requirements.
We recommend that the PBS Commissioner for GSA-leased space: a. Review and update current and future lease agreements to ensure that they clearly identify the required MERV air filters and preventive maintenance schedules; b. Ensure that lessors maintain and provide required preventive maintenance records and provide timely access to mechanical rooms; and c. Ensure that PBS representatives inspect mechanical rooms and preventive maintenance records to ensure that air filters meet MERV requirements.
PBS Did Not Always Follow CDC and Internal Guidance to Limit the Risk of COVID-19 Exposure
Issue timely notification of all COVID-19 incidents in GSA-controlled facilities to all occupant agencies, contractors, and visitors. In addition, take steps to maximize awareness of COVID-19 incidents in GSA-controlled facilities.
Ensure that tenant agencies are aware of the requirement to immediately notify PBS of COVID-19 incidents.
Ensure that Scope 3 – COVID-19 Cleaning is followed whenever a COVID-19 incident occurs in a GSA-controlled facility.
Ensure inspection procedures and guidance are clear, concise, and include appropriate processes to conduct and document inspections for Scope 3 – COVID-19 Cleaning. Also, ensure that inspection requirements are communicated to staff.
Implement quality assurance procedures that ensure PBS’s consistent oversight of the delivery of safe, efficient, and effective custodial services.